Table of Contents

PROPOSED ACTION ...... 3

BACKGROUND ...... 3

PURPOSE AND NEED FOR THE ACTION ...... 5

ALTERNATIVES ...... 5

Alternative A – No Action ...... 5

Alternative B – Proposed Action ...... 5

AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES ...... 7

Natural Resources ...... 10

Visitor Use and Experience ...... 24

Cultural Resources ...... 25

Refuge Management and Operations ...... 26

Socioeconomics ...... 28

MONITORING ...... 31

SUMMARY OF ANALYSIS ...... 31

Alternative A – No Action alternative ...... 31

Alternative B – Proposed action alternative ...... 31

LIST OF PREPARERS ...... 32

CONSULTATION AND COORDINATION ...... 32

State Coordination ...... 32

Tribal Consultation ...... 32

Public Outreach ...... 32

REFERENCES ...... 33 APPENDIX A ...... 38

CULTURAL RESOURCES ...... 38

FISH AND WILDLIFE ...... 38

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 2 Draft Environmental Assessment Expansion of waterfowl hunting on Don Edwards San Francisco Bay National Wildlife Refuge

Date: April 2021 This Draft Environmental Assessment (EA) is being prepared to evaluate the effects associated with the Proposed Action and complies with the National Environmental Policy Act (NEPA) under Council on Environmental Quality regulations (40 CFR 1500-1509) and Department of the Interior (43 CFR 46; 516 DM 8) and U.S. Fish and Wildlife Service (USFWS; 550 FW 3) regulations and policies. The NEPA requires examination of the effects of proposed actions on the natural and human environment. Appendix A outlines all law and executive orders evaluated through this EA. Proposed Action The U.S. Fish and Wildlife Service (USFWS; Service) is proposing to expand waterfowl hunting opportunities on Don Edwards San Francisco Bay National Wildlife Refuge (San Francisco Bay NWR; Refuge) following the 2012 Comprehensive Conservation Plan (CCP) (U.S. Fish and Wildlife Service, 2012). The expansion includes the following additions the Refuge’s already available waterfowl hunting:

· Expand the hunting boundary of the Greco Island hunt unit to include an additional 500 acres of waterfowl hunting (see Figure 1). · Open waterfowl hunting on the 460-acre Pond A6 (see Figure 1).

A proposed action may evolve during the NEPA process as the Service refines its proposal and gathers feedback from the public, tribes, and other agencies. Therefore, the final Proposed Action may be different from the original. The Proposed Action will be finalized at the conclusion of the public comment period for the EA. Background NWRs are guided by the mission and goals of the National Wildlife Refuge System (NWRS), the purposes of an individual refuge, Service policy, and laws and international treaties. Relevant guidance includes the NWRS Administration Act of 1966, as amended by the NWRS Improvement Act of 1997, Refuge Recreation Act of 1962, and selected portions of the Code of Federal Regulations and Fish and Wildlife Service Manual.

The refuge was established pursuant to 86 Stat. 399, dated June 30, 1972, for the purpose of “...the preservation and enhancement of highly significant wildlife habitat...for the protection of migratory waterfowl and other wildlife, including species known to be threatened with

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 3 extinction, and to provide an opportunity for wildlife-oriented recreation and nature study...” (86 Stat. 399).

The mission of the NWRS, as outlined by the National Wildlife Refuge System Administration Act (NWRSAA), as amended by the NWRS Improvement Act (16 U.S.C. 668dd et seq.), is

“... to administer a national network of lands and waters for the conservation, management and, where appropriate, restoration of the fish, wildlife, and plant resources and their habitats within the United States for the benefit of present and future generations of Americans.”

Additionally, the NWRSAA mandates the Secretary of the Interior in administering the NWRS (16 U.S.C. 668dd(a)(4)) to

· Provide for the conservation of fish, wildlife, and plants, and their habitats within the NWRS; · Ensure that the biological integrity, diversity, and environmental health of the NWRS are maintained for the benefit of present and future generations of Americans; · Ensure that the mission of the NWRS described at 16 U.S.C. 668dd(a)(2) and the purposes of each refuge are carried out; · Ensure effective coordination, interaction, and cooperation with owners of land adjoining refuges and the fish and wildlife agency of the states in which the units of the NWRS are located; · Assist in the maintenance of adequate water quantity and water quality to fulfill the mission of the NWRS and the purposes of each refuge; · Recognize compatible wildlife-dependent recreational uses as the priority general public uses of the NWRS through which the American public can develop an appreciation for fish and wildlife; · Ensure that opportunities are provided within the NWRS for compatible wildlife- dependent recreational uses; and · Monitor the status and trends of fish, wildlife, and plants in each refuge.

In California, 39 refuges provide over 475,000 acres of habitat for wildlife. Eighteen of these refuges, including San Francisco Bay NWR, allow waterfowl hunting. Hunting on Refuge lands as well as hunting on neighboring California Department of Fish and Wildlife (CDFW) lands is an existing activity that took place before the Refuge’s establishment.

In fact, the Master Plan developed in 1974 for the Refuge states: “Waterfowl hunting is a traditional sport on San Francisco Bay, and a substantial amount of waterfowl hunting still occurs within the area to be acquired for the Refuge. Under existing policy and legal authority this activity may continue in the future as long as harvestable populations exist and hunting remains compatible with Refuge objectives.” After Refuge establishment, regulated hunting was continued on certain areas of the refuge. Outside of the Refuge, opportunities to hunt waterfowl in South San Francisco Bay are limited, making the Refuge a valuable resource for waterfowl

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 4 hunters. As of the 2019 hunt season, there were approximately 13,500 waterfowl hunt visits on the Refuge (U.S. Fish and Wildlife Service, n.d.). Approximately 10,000 acres of the 30,000 acres on the refuge are currently open to waterfowl hunting (U.S. Fish and Wildlife Service, 2020a). This acreage includes managed ponds, tidal areas and the open bay. The hunting program is administered by the Refuge but complies with CDFW regulations and standards. Purpose and Need for the Action The purpose of this Proposed Action is to continue to provide compatible wildlife-dependent recreational opportunities on San Francisco Bay NWR and to expand waterfowl hunting on the Refuge. The need of the Proposed Action is to meet the Service’s priorities and mandates as outlined by the NWRSAA to “recognize compatible wildlife-dependent recreational uses as the priority general uses of the NWRS” and “ensure that opportunities are provided within the NWRS for compatible wildlife-dependent recreational uses.” 16 U.S.C. 668dd (a) (4). The objectives of waterfowl hunting on the Refuge are consistent with the mission of the NWRS and the natural resources and visitor services goals for the Refuge, which can be found in the Final CCP/EA for Don Edwards San Francisco Bay NWR (U.S. Fish and Wildlife Service, 2012), which is hereby incorporated by reference. Alternatives

ALTERNATIVE A – NO ACTION Under the No Action Alternative, the Service would not expand the hunt boundary of the Greco Island hunt unit, nor would the Service open waterfowl hunting on Pond A6. The Service would continue to allow existing waterfowl hunting on approximately 10,000 acres of the Refuge in accordance with state and Refuge-specific regulations. Seasons, hours, bag limits, and other rules for hunting on the Refuge would be unchanged under this alternative, and such details are described by CDFW (California Department of Fish and Wildlife, 2020) and the Refuge website (U.S. Fish and Wildlife Service, 2020b).

Opportunities for other visitor activities on the refuge would still include all six priority public uses: hunting, fishing, interpretation, environmental education, wildlife observation, and wildlife photography. More information on visitor services, including hunting, that are offered on the Refuge can be found in the Final CCP/EA (U.S. Fish and Wildlife Service, 2012) and on the Refuge’s website (U.S. Fish and Wildlife Service, 2020a).

ALTERNATIVE B – PROPOSED ACTION The Refuge has prepared a Hunt Plan (U.S. Fish and Wildlife Service, 2021a) describing the hunting opportunities proposed at San Francisco Bay NWR, which is presented in this document as the Proposed Action Alternative; the Hunt Plan is also incorporated by reference.

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 5 Under the Proposed Action Alternative, the Service would expand waterfowl hunting on two units of the Refuge: (1) expanding the hunt boundary of Greco Island to include the 500-acre tidal portion of the unit and (2) opening waterfowl hunting on the 460-acre Pond A6 (see Figure 1). The rules and regulations associated with waterfowl hunting, which is already permitted on other areas of the Refuge, would remain consistent with those already in place, as described in the No Action Alternative.

Hunting on Pond A6 and Greco Island will be open seven days a week, and access to Pond A6 is only available from adjacent sloughs (Guadalupe and Alviso) during appropriate tide windows that allow navigation through the levee openings. Hunting on Greco Island (including the expanded 500 acres) will remain as is currently operated.

Alviso Pond A6 · Located near the Mowry Slough Unit in South San Francisco Bay between Mowry Slough and Coyote Creek · Hunting is allowed seven days a week · Access is by boat only—boats must access from the bay and hunt from the boat inside the pond · Shooting from levees is prohibited · No land or tidal marsh access is allowed, except to retrieve downed birds (due to endangered species present)

Greco Island · Located on the west side of the San Francisco Bay, north of Dumbarton Bridge · Hunting is allowed seven days a week · Hunting is allowed by boat in tidal areas (including Redwood Creek, Smith, Steinberger, and Corkscrew sloughs) · No land or tidal marsh access is allowed, except to retrieve downed birds (due to endangered species present)

Specific regulations for the other hunt units of the Refuge are in the 2021 Hunt Plan (U.S. Fish and Wildlife Service, 2021a). Additionally, regulations will be published in the Federal Register as part of the 2021-2022 Refuge-Specific Hunting and Sport Fishing Regulations.

The Proposed Action meets the purpose and need by expanding compatible wildlife-dependent recreational opportunities while maintaining sustainable waterfowl populations. This alternative offers increased opportunities for public hunting and fulfills the Service’s mandate under the NWRS Improvement Act of 1997. The Service has determined that the Proposed Action (the Hunt Plan) is compatible with the purposes of the Refuge; the mission of the NWRS; and meets the Service’s priorities and mandates as outlined by the NWRSAA (16 U.S.C. 668dd (a) (4)), and is consistent with and supports the Refuge’s CCP.

Mitigation Measures to Avoid Conflicts:

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 6 · Population monitoring will be reviewed annually by the Refuge to ensure that harvests are not unacceptably impacting the targeted populations. The program will be modified accordingly. · The Refuge will maintain an effective law enforcement program to protect Refuge resources and the visiting public. Environmental education and outreach will remain a key component and priority for the Refuge. Hunting outreach brochures will be made available to the public at the Refuge offices, through Refuge law enforcement officers and other staff and via the Refuge website. · The use of retrieving dogs will be permitted and encouraged in all areas open to hunting. Dogs must be under control at all times. Dogs will be required to be kept on leash, except when engaged in authorized hunting activities and under the direct voice control of a licensed hunter. · In accordance with the Archaeological Resources Protection Act (16 U.S.C. 470aa), the disturbance of archaeological or historical sites, and the removal of artifacts are prohibited. The excavation, disturbance, collection, or purchase of historical, ethnological, or archaeological specimens or artifacts, or mementos from the Refuge is prohibited. · Boats used for hunting will be limited to navigable sloughs, open waters, and specified managed ponds. Boats must adhere to the California Boating Law. This information will be available to the public at appropriate access points on the Refuge, the headquarters visitor center, Alviso Environmental Educational Center, and via the Refuge’s website. Affected Environment and Environmental Consequences This section is organized by affected resource categories and for each affected resource discusses both (1) the existing environmental and socioeconomic baseline in the action area for each resource and (2) the effects and impacts of the Proposed Action and any alternatives on each resource. The effects and impacts of the Proposed Action considered here are changes to the human environment, whether adverse or beneficial, that are reasonably foreseeable and have a reasonably close causal relationship to the Proposed Action or alternatives. This EA includes the written analyses of the environmental consequences on a resource only when the impacts on that resource could be more than negligible and therefore considered an “affected resource.” Any resources that will not be more than negligibly impacted by the action have been dismissed from further analyses.

The Refuge consists of approximately 30,000 acres located at the southern end of the South San Francisco Bay and extends into Alameda, Santa Clara, and San Mateo Counties (see Figure 1). The Refuge is primarily managed ponds, followed by tidal wetlands, subtidal and mudflat (bay), grasslands, and developed areas. The waterfowl hunt program on the Refuge covers managed ponds, tidal areas, and the open bay. The Proposed Action would takes place on the following habitats: (1) opening hunting on Pond A6 primarily overlaps with tidal and pond habitat, and (2) expanding hunting on Greco Island would include tidal and salt water marsh habitats (U.S. Fish

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 7 and Wildlife Service, 2012). See Figure 1 for a map of the general area and proposed project site on the Refuge.

For more information regarding the general characteristics of the Refuge’s environment, please see Chapter 3 of the Refuge’s Final CCP, which can be found here: https://ecos.fws.gov/ServCat/Reference/Profile/43999. For more information on the environmental consequences of the Proposed Action, see the EA done in conjunction with the Refuge’s CCP (same link as above). Therefore, that EA provides additional specific analysis of the Proposed Action.

The following resources either (1) do not exist within the project area or (2) would either not be affected or only negligibly affected by the Proposed Action:

· Hydrology · Geology and Soils · Air Quality · Water Quality · Hazardous Materials · Wilderness or Other Special Designation · Floodplains

As such, these resources are not analyzed in this EA.

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 8 Figure 1. Map of the proposed hunt expansion areas on Don Edwards San Francisco Bay NWR.

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 9 NATURAL RESOURCES Species to be hunted — Geese, ducks, and coots Affected Environment Description of Relevant General Features of Affected Environment More than 32 species of waterfowl may use habitats within the Refuge for breeding, wintering, or during migration. (Harvey, et al., 1988) reported that wintering waterfowl in the South Bay in 1981 exceeded 75,000 individuals, with more ducks on ponds than in the bay, especially from January through April. Surveys in 1987–1990 revealed approximately 57,000 dabbling ducks and 220,000 diving ducks (Goals Project, 1999) in the San Francisco Bay Area. From 2013– 2018, waterfowl and coots counted in the South Bay salt ponds ranged from 37,575 to 139,961 (Strong, 2018). The more abundant species in South Bay ponds include 89 percent of the bay’s northern shovelers (Anas clypeata), 67 percent of the ruddy ducks (Oxyura jamaicensis)), half of the buffleheads (Bucephala albeola), and 17 percent of the canvasbacks (Aythya valisineria) wintering in the bay (Accurso, 1992; Takekawa, et al., 2001).

The habitats of the South Bay support eight regularly nesting waterfowl species: the mallard (Anas platyrhynchos), gadwall (Anas strepera), and Canada goose (Branta canadensis) are fairly common breeders, while the cinnamon teal (Anas cyanoptera), northern pintail (Anas acuta), ruddy duck, lesser scaup (Aythya affinis), and northern shoveler breed in smaller numbers. Several other species, including the green-winged teal (Anas crecca), blue-winged teal (Anas discors), canvasback, and redhead (Aythya americana), have been recorded breeding only a few times in the South Bay (Bousman, 2007).

American coots (Fulica Americana) breed in freshwater wetlands, channels, and ponds in and around emergent vegetation in a number of locations throughout the South Bay. Coot populations are augmented substantially during winter, when this species occurs by the hundreds or low thousands on lower-salinity ponds (Anderson, 1970), sewage treatment plant ponds, Shoreline Lake, and other open-water locations (U.S. Fish and Wildlife Service, 2012).

A complete list of birds that occur on the Refuge can be viewed in Appendix E of the Final CCP/EA and available data on waterbird use in the South Bay ponds can be viewed in Appendix G of the same document (U.S. Fish and Wildlife Service, 2012).

Description of Relevant Environmental Trends and Planned Actions

Flyway San Francisco Bay NWR is located within the Pacific Flyway (PF) and supports large populations of waterfowl and waterbirds each year. The 2019 total duck breeding population index for California from the state waterfowl breeding population survey was estimated at 470,961 ducks; this is aligned with the three year average of 472,224 ducks from 2017–2019 (Olson, 2020). Total duck and goose harvest in the United States in 2019 was estimated at 9,720,800 ducks and 2,675,775 geese (Olson, 2020). Annual duck and goose harvests in 2019

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 10 within the PF was 2,143,400 ducks and 434,900 geese on average. There were 141,346 active adult duck hunters and 87,997 active adult goose hunters within the PF in 2019.

Total coot harvest in the United States in 2019 was estimated at 242,580 coots; annual harvests in the PF were estimated at 22,326 coots in 2019. The number of adult coot hunters was not estimated in the 2020 Pacific Flyway Data Book (Olson, 2020). Harvest numbers are unknown on the Refuge because there are no hunter check-in stations and reporting harvest numbers from the open bay is voluntary. However, the Refuge estimates 3,500 waterfowl hunters visited the Refuge during the 2019 hunt season.

Climate Change The environmental trends of wildlife in response to climate change are described the section Non-Target Wildlife and Aquatic Species.

Restoration Projects By restoring parts of the Refuge to a mix of tidal marsh, mudflat, managed pond, open water, and other wetland habitats, there are anticipated benefits to waterfowl and other wildlife. For example, the South Bay Salt Pond Restoration Project will improve the quality and quantity of waterfowl habitat on the Refuge. More details on this project and its anticipated benefits to habitat can be found in the Habitat and Vegetation section of this document.

Individual wildlife may also be negatively affected by ongoing restoration projects. However, restoration activities are expected to benefit the long-term population of tidal marsh species, including listed species such as the California Ridgway’s rail (Rallus longirostris obsoletus) and the salt marsh harvest mouse (Reithrodontomys r. raviventris). There could be a temporary loss of tidal marsh habitat from inundated areas where breaching occurs. Restoration activities could disturb and flush clapper rails and salt marsh harvest mice from the area. In the long-term, additional tidal marsh habitat would off-set the temporary loss of habitat. Mitigation measures adopted as part of the ongoing restoration projects to reduce impact to individuals includes surveying for presence or absence of individuals; providing a buffer near nest locations; avoiding activities during the nesting season; trapping and transplanting mice to other sites; installing barrier fence to prevent re-entry; and slow flooding to allow mammals to seek refugia in higher elevation vegetation (U.S. Fish and Wildlife Service, 2012).

Environmental Consequences Description of Affected Resource Harvest numbers are unknown on the Refuge because there are no hunter check-in stations and reporting harvest numbers from the open bay is voluntary. However, the Refuge estimates that 3,500 waterfowl hunters visited the refuge during the 2019 hunt season (U.S. Fish and Wildlife Service, n.d.).

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 11 Impacts on Affected Resource

Alternative A — No Action The continued implementation of the hunt program on the Refuge fulfills the NWRS mission and Refuge-specific purpose of providing wildlife-dependent recreation to the public. Under the No Action Alternative, the Service would not open an additional 960 acres for the hunting of ducks, geese, and coots. The Refuge would remain open for waterfowl hunting on approximately 10,000 acres of the Refuge as described in the Final CCP/EA (U.S. Fish and Wildlife Service, 2012), on the Refuge website (U.S. Fish and Wildlife Service, 2020b), and in their Hunt Plan (U.S. Fish and Wildlife Service, 2021a).

Hunting directly results in the disturbance, injuring, and killing of waterfowl. Waterfowl hunting on the ponds, open bay, and navigable sloughs will result in the direct loss of waterfowl and migratory species protected under the Migratory Bird Treaty Act. It is estimated that there were 3,500 hunter visits during the 2019 hunt season that use the 10,000 acres of hunt area within the Refuge. Hunting on the Refuge requires the purchase of a Duck Stamp, is regulated by the state, and law enforcement monitoring is used to control over-harvest.

Hunting can also alter wildlife behavior (i.e., foraging time), population structure, and wildlife distribution patterns (Owens, 1977; Raveling, 1979; White-Robinson, 1982; Thomas, n.d.; Madsen, 1985; Bartelt, 1987; Cole & Knight, 1990). There also appears to be an inverse relationship between the numbers of birds using an area and hunting intensity (DeLong, 2002). In Connecticut, lesser scaup was observed to forage less in areas that were heavily hunted (Cronan 1957); following the close of hunting season, ducks generally increased their use of the hunt area. However, use was lower than before the hunting season began.

Human disturbance associated with hunting includes loud noises and rapid movements, such as those produced by shotguns and boats powered by outboard motors. This disturbance, especially when repeated over a period of time, compels waterfowl to change food habits, feed only at night, lose weight, or desert feeding areas (Wolder, 1993; Madsen, 1995). Prolonged and extensive disturbances may cause large numbers of waterfowl to leave disturbed areas and migrate elsewhere (Paulus, 1984; Madsen, 1995). These impacts can be reduced by the presence of adjacent sanctuary areas where hunting does not occur and birds can feed and rest relatively undisturbed. Sanctuaries or non-hunt areas have been identified as the most common solution to disturbance problems caused by hunting (Havera, et al., 1992). As such, the areas of the Refuge not opened to hunting (approximately 20,000 acres) will remain closed to hunting activities to provide adequate sanctuaries for wildlife. Recreational hunting will remove individual animals, but it is not anticipated to negatively affect wildlife populations (U.S. Fish and Wildlife Service, 2012).

Most hunting units of the Refuge are accessible by boat. As such, there are disturbances to waterfowl associated with both motorized and non-motorized boats. Though motorized boats generally have a greater impact on waterfowl, even non-motorized boat use can alter distribution, reduce the use of particular habitats by waterfowl and other birds, alter feeding behavior and

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 12 nutritional status, and cause premature departure from areas (Knight & Cole, 1995). Disturbance to birds, in general, is reduced when boats travel at or below the five-mile-per-hour speed limit.

By its very nature, hunting has very few positive effects on the target species while the activity is occurring. However, despite the potential impacts of hunting, a goal of the Refuge is to provide visitors of all ages an opportunity to enjoy wildlife-dependent recreation.

More information on the impacts of hunting on waterfowl can be found in the EA for the Final CCP (U.S. Fish and Wildlife Service, 2012).

Alternative B — Proposed Action Expanding waterfowl hunting on the Refuge to include the 500-acre tidal portion of Greco Island and the 460-acre Pond A6 will have the same impacts on waterfowl as described in the No Action Alternative above. However, because the existing hunt program on the Refuge already includes 10,000 acres of waterfowl hunting, opening an additional 960 acres will have minimal additional impacts on waterfowl species. Additionally, because annual Pacific Flyway harvest regulations are designed to ensure that viable populations of waterfowl are sustained over the long term, the opening of these 960 acres would be reviewed annually by the Service to ensure that overall populations of waterfowl remain healthy in the future. Waterfowl sanctuaries will remain available in the areas of the Refuge not open to hunting, thus minimizing the impacts on hunted species.

Non-Target Wildlife and Aquatic Species Affected Environment Description of Relevant General Features of Affected Environment San Francisco Bay NWR provides important foraging and roosting habitat for more than one million waterbirds each year, supporting large proportions of the populations of some shorebird and duck species (Accurso, 1992; Harrington & Perry, 1995; Page, et al., 1999; Stenzel, et al., 1989; Stenzen & Page, 1988; Takekawa, et al., 2001). Specifically, six major bird groups are identified as using the South Bay for nesting, foraging, roosting, etc.: 1) shorebirds; 2) waterfowl (ducks and geese); 3) large waders (herons, egrets, and ibis) and other piscivores (fish-eating grebes, cormorants, and pelicans); 4) colonial-nesting waterbirds (gulls, terns, and some shorebirds); 5) other waterbirds (eared grebes (Podiceps migricollis), coots, and rails); and 6) landbirds (including raptors and passerines).

By comparison, relatively few species of mammals occur in the South Bay, owing to the intense disturbance and habitat conversion that has occurred within the area. The salt marsh wandering shrew and Federally listed salt marsh harvest mouse occur in the Refuge, primarily in pickleweed-dominated salt marshes, and are the primary focus of mammal research on the Refuge.

Relatively few species of reptiles and amphibians occur in the Refuge, including the western fence lizard (Sceloporus occidentialis), garter snakes (Thamnophis couchi, T. elegans, and T.

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 13 sirtalis), gopher snakes (Pituophis melanoleucus), and southern alligator lizards (Elgaria multicaranata), the Federally listed California tiger salamander (Ambystoma californiense), Pacific treefrogs (Pseudocris regilla), and slender salamanders (Batrachoseps attenuates).

There is also a wide diversity of fish and invertebrate species found on the Refuge, described in more detail in the Final CCP/EA. For a complete list of species on the Refuge, see Appendix E of the Final CCP/EA (U.S. Fish and Wildlife Service, 2012).

Description of Relevant Environmental Trends and Planned Actions

Waterbird populations According to the 2019 San Francisco Bay NWR Complex Natural Resource Management Plan (U.S Fish and Wildlife Service, 2018), the status of waterbirds on the Refuge is considered “very good” with an “increasing” trend. More specifically, a 2016 study of wintering shorebirds in the South Bay reported bird abundance trends between 2002 and 2015 from 5,055 pond surveys during 13 field seasons (De La Cruz, et al., 2018). The team observed 98 species of waterbirds. Waterfowl (dabbling and diving ducks, 17 percent each), shorebird (small shorebirds, 39 percent; medium shorebirds, 10 percent), and gull (11 percent) guilds represented the most abundant bird taxa in ponds studied across all years. Peak waterbird abundances occurred during winter (December through February). Total winter waterbird abundance increased nonlinearly over the study period, more than doubling from 98,151 ± 38,826 (mean ± 95 percent confidence interval) in 2002 to 235,936 ± 16,564 in 2014 (De La Cruz, et al., 2018).

Restoration Projects The South Bay Salt Pond Restoration project will have a positive net benefit to the ecosystem by restoring natural habitat for endangered species and migratory birds. See the relevant environmental trends and planned actions for “Species to be hunted—geese, ducks, and coots” for more details on the trends and actions associated with non-target wildlife from restoration projects.

Climate Change Via sea level rise, rising temperatures, and the increased frequency of drought (California Landscape Conservation Cooperative, et al., 2018), climate change on the Refuge has the potential to decrease the availability of and/or degrade the quality of wildlife habitat. Not only are habitats expected to shift, but climate change is also expected to affect the timing of bird migration and when leaves begin to bud (IPCC, 2007). Climate change can also result in physiological changes, phenological (lifecycle) changes, range shifts, community changes, ecosystem process shifts, and multiple stressor conditions for wildlife (Parmesan & Galbraith, 2004). Tidal habitat for wildlife at the shoreline could disappear, forcing species to move onto higher ground, possibly competing with other wildlife for habitat.

Projected changes in the marine environment associated with climate change are expected to substantially impact seabird populations specifically (California Landscape Conservation Cooperative, et al., 2018). These changes include rising sea surface temperatures, ocean

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 14 acidification, and changes in timing and strength of upwelling and ocean circulation patterns. Disruptions in the food web and changes in the timing of physical processes in the marine environment resulting from these climate changes appear to already be leading to changes in seabird reproductive success and survival. Seabird population metrics and distributions appear to be shifting in response to changes in the locations of high-productivity areas and other conditions. There have been radical swings in ocean conditions and seabird populations observed in recent years, with some seabird species (such as Brandt’s cormorant) crashing dramatically and important prey (such as juvenile rockfish) increasing to record numbers (California Landscape Conservation Cooperative, et al., 2018).

Adverse effects from climate change on the native fishes of the San Francisco Bay Area are thought to be secondary to the impacts of estuarine alteration, agriculture, and upstream dam operations. However, the relative effect of climate change on these species will likely grow in an increasingly warmer and drier California, conditions that will generally favor alien fishes over native species (Moyle, et al., 2013; Quinones & Moyle, 2013).

Climate change will likely result in changes in vegetation and habitat availability for marsh- dependent species (California Landscape Conservation Cooperative, et al., 2018) such as Ridgway’s rail, salt marsh harvest mouse, common yellowthroat, and song sparrow (Takekawa, et al., 2013).

Environmental Consequences Impacts on Affected Resource

Alternative A — No Action Impacts on non-target wildlife due to hunting include short-term disturbances related to increased human presence and noise associated with hunting. Presumably, the same behavioral changes seen in waterfowl (as described in the “Species to be Hunted – Geese, Ducks, and Coots” section above) would also occur for non-hunted wildlife. Specifically, this includes behavioral changes as a result of hunting-related noises and movements. These effects are relatively minor on the Refuge since they can be reduced by the availability of adjacent sanctuary areas where hunting does not occur, and both hunted and non-hunted wildlife can feed and rest relatively undisturbed. Sanctuaries or non-hunt areas have been identified as the most common solution to disturbance problems caused by hunting (Havera, et al., 1992). As such, the areas of the Refuge not opened to hunting (approximately 20,000 acres) will remain closed to hunting activities to provide adequate sanctuaries for wildlife. In general, recreational hunting will remove individual animals but is not anticipated to negatively affect wildlife populations (U.S. Fish and Wildlife Service, 2012).

Potential impacts to wildlife may also occur through the use of boating to facilitate hunting. Both motorized and non-motorized boating can alter wildlife behavior. Though motorized boats generally have a greater effect on wildlife, even non-motorized boat use can alter distribution, reduce the use of particular habitats by waterfowl and other birds, alter feeding behavior and

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 15 nutritional status, and cause premature departure from areas (Knight and Cole 1995). However, compared to motorboats, canoes and kayaks appear to have less disturbance effects on most wildlife species (DeLong, 2002). Disturbance to birds, in general, is reduced when boats travel at or below the five-mile per hour speed limit.

Hunted species may possibly compete with non-game wildlife for habitat. While each species may occupy a unique niche, there is a finite amount of space available to satisfy various habitat requirements of such as water, food, cover, and breeding. Although some disturbance to non- hunted wildlife will occur during the hunting seasons, measures are taken to minimize potentially negative effects to wildlife populations using the refuge. For example, hunting on the Refuge is seasonal, restricted (in some hunt units) to only three days a week, and harvest regulations (set by the state and within Federal framework guidelines) are adopted by the Refuge to ensure healthy wildlife populations in the future.

Although hunting results in numerous adverse effects on non-hunted species, hunting provides a long-term benefit by increasing public appreciation for and stewardship of wildlife resources. It also enhances visitors’ understanding of the importance of habitat conservation.

Alternative B — Proposed Action The impacts described under the No Action Alternative are anticipated to occur under this Alternative as well. However, because hunting on the Refuge is already open to approximately 10,000 acres, the addition of 960 acres under this Alternative will only incrementally increase these impacts on non-hunted wildlife species.

Threatened and Endangered Species, and Other Special Status Species Affected Environment Description of Relevant General Features of Affected Environment There are 32 threatened, endangered, or other special status species found on the Refuge. Only the Federally or state threatened or endangered species that overlap with the Proposed Action area are described in detail below, but more information about other special status species on the Refuge can be found in the Final CCP/EA (U.S. Fish and Wildlife Service, 2012) and Biological Evaluation (U.S. Fish and Wildlife Service, 2021b).

Birds Two special-status rail species can be found in the South Bay: the California Ridgway’s rail (Rallus longirostris obsoletus) and the California black rail (Laterallus jamaicensis coturniculus). The Federal and state endangered California Ridgway’s rail is a secretive marsh bird endemic to the marshes of San Francisco Bay. The California Ridgway’s rail nests in salt and brackish marshes along the edge of the bay and are most abundant in extensive salt marshes and brackish marshes dominated by cordgrass, pickleweed, and marsh gumplant, and containing complex networks of tidal channels (Harvey, 1980). Shrubby areas adjacent to or within tidal marshes are important for predator avoidance at high tides. Breeding-season surveys of South San Francisco Bay marshes for California Ridgway’s rails through the early 1990s indicated that

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 16 the most substantial populations of rails in the South Bay were predictably in the largest sections of tidal salt marsh.

The California black rail, listed as threatened in California, is a small rail that inhabits tidal, brackish, and freshwater marshes. Black rails reportedly bred in the Alviso area in the early 1900s (Wheelock, 1916), but currently are not known to breed in the South Bay.

The Federally threatened western snowy plover (Charadrius alexandrinus nivosus) breeds and forages at several sites within the Refuge, primarily at the Eden Landing, Ravenswood, and West Bay complexes. The western snowy plover also uses ponds for breeding habitat in the South Bay; they were first recorded breeding in ponds in 1918 (Harvey, et al., 1992), and they currently nest on sparsely vegetated pond levees and islands, at pond edges, and on salt panne areas within diked marsh in the South Bay (Page, et al., 2000), with the highest concentration of breeding occurring at the Eden Landing Ecological Reserve. By 1990, approximately 10 percent of the California snowy plover population bred in the San Francisco Bay ponds, primarily in the South Bay (Page, et al., 2000; Page, et al., 1991).

The South Bay is also an important post-breeding staging area for the California least tern (Sterna antillarum browni). Recent breeding by small numbers has occurred in the Refuge at the Eden Landing complex, and species forage and roost in a number of ponds in the Refuge, especially Alviso ponds in the vicinity of Moffett Field. Both adult and juvenile least terns roost on pond levees (both outboard levees and interior levees between ponds), as well as boardwalks and other structures within ponds.

Fish The Federally threatened North American green sturgeon (Southern Distinct Populations Unit; Acipenser medirostris) is a long-lived, slow-growing fish and the most marine-oriented of the sturgeon species. The green sturgeon ranges from Ensenada, Mexico, to the Bering Sea in marine waters and commonly occurs in coastal waters from San Francisco Bay to Canada. However, its occurrence in the South San Francisco Bay is expected to be infrequent.

The Federally threatened steelhead trout (California Central Coast ESU; Oncorhynchus mykiss) migrate through the South Bay and Refuge into freshwater streams as adults, typically from December through April. The Central California Coast Distinct Population Segment steelhead are not known to occur within any of the ponds, but they are present in Alviso slough, Old Alameda Creek, Coyote Creek, San Francisquito Creek, and associated marshes and small channels within the Refuge boundary. Suitable spawning habitat is not present in the Refuge, but adults move through the area to spawn upstream. Migration of this species through the Refuge occurs from December-April.

Mammals The Federally endangered salt marsh harvest mouse (Reithrodontomys r. raviventris) is a small mouse endemic to salt marshes of San Francisco Bay. These mice are dependent on dense vegetative cover, usually in the form of pickleweed and other salt-dependent or salt-tolerant

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 17 vegetation in tidal and diked salt marshes (Fisler, 1965; Shellhammer, et al., 1988; Shellhammer, 1982; Shellhammer, 2000; Johnson & Shellhammer, 1988). Grasslands adjacent to pickleweed marshes are used in the spring when new growth affords suitable cover and possibly forage (Johnson & Shellhammer, 1988). Salt marsh harvest mice may also use adjacent grasslands regularly to avoid high tide events. However, only a small percentage of the edge of the South Bay has grassland or other adjacent cover. On the highest winter tides, the lack of high-tide refugia exposes salt marsh harvest mice to intense predation, and numerous small mammals (many of which are likely salt marsh harvest mice) have been observed being depredated by gulls, herons, egrets, and raptors on such high tides in the South Bay.

Plant Species There are four Federal or state threatened or endangered plant species identified on or near the Refuge, but none that overlap with the Proposed Action area or are considered likely present. Palmate-bracted bird’s-beak (Cordylanthus palmatus) and Point Reyes meadowfoam (Limnanthes douglasii ssp. sulphurea) overlap with vernal pools and upland habitat and are considered unlikely to occur on the Refuge; Contra Costa goldfields (Lasthenia conjugens) is present on the Refuge but does not occur within the Proposed Action area; and California seablite (Suaeda californica) overlaps with coastal tidal marsh habitat but is unlikely to occur on the refuge and blooms from May–October, which does not overlap with the hunting season. More information on special status plant species can be found in Section 3.4.4 of the Final CCP (U.S. Fish and Wildlife Service, 2012) and the Biological Evaluation for this EA (U.S. Fish and Wildlife Service, 2021b).

Description of Relevant Environmental Trends and Planned Actions Since 2005, Western snowy plover observed during the breeding season in one recovery unit has increased from 124 (2004) to 208 (2016), with the majority found at California Department of Fish and Wildlife’s Eden Landing preserve. Refuge lands held 37 percent (N = 77 individuals counted) of the total South Bay count in 2016 (U.S Fish and Wildlife Service, 2018).

Specifically, the 2017 and 2018 individual detections of California Ridgway’s rail in one sub- area of the survey exceeded the extrapolated bay-wide population estimate of 1,167 individuals. As such, the Ridgway’s rail population is expected to be increasing (U.S Fish and Wildlife Service, 2018).

Restoration Projects The South Bay Salt Pond Restoration Project will have a positive net benefit to the ecosystem by restoring natural habitat for endangered species and migratory birds. See the relevant environmental trends and planned actions for “Species to be hunted—geese, ducks, and coots” for more details on the trends and actions associated with non-target wildlife from restoration projects.

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 18 Avian predation The majority of western snowy plover nest failures in the South Bay can be attributed to depredation; remote camera monitoring has revealed depredation of nests by a variety of species including California gulls (Larus californicus), common ravens (Corvus corax), northern harriers (Circus cyaneus), red-tailed hawks (Buteo jamaicenis), and gray fox (Urocyon cinereoargenteus). Similarly, avian predators are expected to contribute to decreased population sizes of California least terns (U.S. Fish and Wildlife Service, 2012; U.S Fish and Wildlife Service, 2018).

Urban development The most fundamental reason for the decline of the salt marsh harvest mouse is loss of habitat through filling (i.e., destruction), subsidence, and vegetation changes (U.S. Fish and Wildlife Service, 1984; Bias & Morrison, 1993; Shellhammer, 2000). Without appropriate cover in marshes to serve as a refugia zone, salt marsh harvest mice cannot escape during flooding or high tides. The filling, diking, and land conversion of areas surrounding the Refuge has similarly contributed to habitat loss, and thus severe population declines, of the California Ridgway’s rail.

Steelhead populations in the South Bay and other areas have declined due to degradation of spawning habitat, introduction of barriers to upstream migration, over-harvesting by recreational fisheries, and reduction in winter flows due to damming and spring flows due to water diversion (U.S. Fish and Wildlife Service, 2008).

Climate Change Gardali et al. (2012) determined vulnerability and climate priority rankings for 358 bird taxa in California, and the California least tern was ranked as highly vulnerable to climate change (California Landscape Conservation Cooperative, et al., 2018). Climate variation influences bird populations both in their breeding and non-breeding areas by affecting important demographic processes, such as breeding success and survival. Increased frequency and intensity of storms, heat exposure, and ocean acidification could negatively impact California least tern feeding and breeding in the San Francisco Bay area (California Landscape Conservation Cooperative, et al., 2018).

Environmental Consequences Impacts on Affected Resource The Service has drafted a Biological Evaluation that addresses potential effects to the California least tern, California Ridgway’s rail, salt marsh harvest mouse, and Western snowy plover from expanding waterfowl hunting on Greco Island and opening waterfowl hunting on Pond A6 (U.S. Fish and Wildlife Service, 2021b). The Service anticipates that while hunting may affect the California Ridgway’s rail and steelhead trout (California Central Coast ESU), there would be no adverse effects to these species. There are no expected impacts on other listed species.

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 19 Alternative A — No Action As described in the “Species to be Hunted” and “Non-Target Wildlife” sections above, impacts on wildlife species due to hunting can be caused by human presence, noise, or disturbance via boats. Impacts on species that are state or Federally listed as threatened or endangered are detailed below.

California least terns and Western snowy plovers use sparsely vegetated pond levees and islands, at pond edges, and on salt panne areas within the South Bay. Disturbance from hunting may occur, temporarily flushing individuals and making them vulnerable to predation. By contrast, there are no anticipated impacts on breeding individuals because the hunting season, which typically opens in mid-October and ends in late January, does not overlap with the least tern and snowy plover breeding season.

The California Ridgway’s rail, California black rail and salt marsh harvest mouse overlap with tidal hunting areas of the Refuge. These areas are only accessible for hunting by boat, but hunters are allowed to walk in tidal marsh vegetation to retrieve downed birds. It is also possible that hunters may trespass into sensitive habitats. Hunting beyond the open bay waters or navigable sloughs in non-designated sites, into the interior of the marsh or other restricted areas, could result in disturbance to endangered species such as the salt marsh harvest mouse, California Ridgway’s rail, and California black rail. The Service will protect these habitats and resources with signage and hunting brochures to increase hunter awareness. Restrictions will be enforced through law enforcement field checks. There may be some disturbance impacts to salt marsh harvest and California Ridgway’s rail, but because the majority of hunting on the refuge is accessible by boat-only, the chance of disturbance in these habitats is minimized.

North American green sturgeon (Southern Distinct Populations Unit; Acipenser medirostris) is not anticipated to occur within the Proposed Action area, so there are no anticipated impacts on this species.

Steelhead trout (California Central Coast ESU; Oncorhynchus mykiss) migrate through the Refuge from December–April and, therefore only briefly have the potential to overlap with the hunting season. Hunting from boats may temporarily flush steelhead trout from their habitat, but there are no anticipated long-term effects on this species under this alternative. Additionally, because the occurrence of this species is expected to be infrequent on the Refuge and only briefly overlapping with the hunting season, impacts are considered minimal.

Alternative B — Proposed Action Under this alternative, 960-acres of hunting would be added to the waterfowl hunt program on the Refuge. Because the habitat of the Proposed Action area is similar to what already exists within the hunt program—primarily tidal and pond habitats—the listed species that occur in the areas proposed for expansion are expected to be the same as those described in Alternative A. For this reason, impacts on listed species under this alternative are the same as Alternative A. It is expected that the addition of 960-acres of hunting will attract more hunt visits on the Refuge. Such growth will increase, though only marginally, these impacts on listed species.

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 20 Habitat and Vegetation (including vegetation of special management concern) Affected Environment Description of Relevant General Features of Affected Environment Five broad-scale habitats are considered to exist within the Refuge, including: 1) pond habitats (active salt ponds, managed ponds, related projects [ponds], salt ponds to be restored), 2) vegetated wetland habitats (tidal wetland, planned or ongoing tidal restoration, muted tidal/diked marsh, fresh water marsh), 3) subtidal and mudflat aquatic habitats, 4) grassland habitats (vernal pools within grassland habitat and upland/grassland habitat), and 5) developed habitats (agricultural and urban development). However, the waterfowl hunt program on the Refuge only covers managed ponds, tidal areas, and the open bay. Specifically, hunt expansion on the Refuge would take place on tidal and pond habitat (opening hunting on Pond A6) and subtidal and salt water marsh habitats (expanding hunt on Greco Island) (U.S. Fish and Wildlife Service, 2012).

Several invasive and myriad non-native weeds are known to occur or may potentially occur within the Refuge (see Appendix D of the Final CCP/EA for a full list) (U.S. Fish and Wildlife Service, 2012). Many of these species out-compete native plants, displacing entire communities of plants and associated wildlife. Within tidal marsh habitat, cordgrass is of particular concern. Non-native smooth cordgrass (S. alterniflora) can easily hybridize with the native Pacific cordgrass (Spartina foliosa), causing the widespread distribution of the hybridized species within a short amount of time. Smooth cordgrass and its hybrids are among the dominant invasive plant species found in the tidal marshes south of the San Francisco Bay Bridge.

Tidal habitat Tidal wetland habitat accounts for the greatest acreage of vegetated habitat after pond habitat, occupying 6,340 acres within the Refuge and found in all the units. According to the Final CCP/EA, tidal vegetated wetland habitat includes salt marsh, brackish marsh, and freshwater marsh habitats (U.S. Fish and Wildlife Service, 2012). Planned or ongoing tidal restoration habitats are formerly disturbed marshes, including former salt ponds actively undergoing tidal restoration or restoration planning that will be restored to salt and/or brackish marsh habitat.

Subtidal habitat Subtidal habitat refers to those areas of open water permanently below low tide. Within the Refuge, there are only a few areas of subtidal habitat—in the West Bay, Alviso, and Newark Units. These areas consist of open water areas on the bay-side of Refuge property or within tidal channels. Eelgrass (Zostera pacifica), an important submerged plant species, can occur in areas containing subtidal habitats.

Saltwater marsh habitat Salt marsh habitat occurs primarily along the outboard (tidal) side of existing levees separating the ponds from the bay. The salt marsh habitat in the South Bay consists primarily of low and middle marsh and is dominated by perennial pickleweed (Sarcocornia pacifica, formerly Salicornia virginica) and cordgrass. There are two species of cordgrass in the South Bay, the

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 21 native Pacific cordgrass (Spartina foliosa) that grows predominantly in the middle marsh, and smooth cordgrass (S. alterniflora), a non-native species from the east coast of North America that can grow farther down into the low marsh and mudflats. A mixture of perennial pickleweed, gumplant (Grindelia stricta), saltgrass (Distichlis spicata), alkali heath (Frankenia salina), sea lavender (Limonium californicum), and other moderately halophytic species that can tolerate occasional high tides dominate the high marsh.

Description of Relevant Environmental Trends and Planned Actions According to the 2018 San Francisco Bay NWR Complex Natural Resource Management Plan (U.S Fish and Wildlife Service, 2018), the Service reasonably expects the extent of tidal marsh to increase by approximately 4,560 acres at Don Edwards San Francisco Bay NWR by 2030. As such, the status of high-quality tidal marsh extent is considered “fair,” and its trend is “increasing,” according to the NRMP’s conservation target analysis (U.S Fish and Wildlife Service, 2018).

Restoration Projects The South Bay Salt Pond Restoration Project (SBSPRP) is the largest tidal wetland restoration project on the West Coast. When complete, the restoration will convert 15,100 acres of former commercial salt ponds at the south end of San Francisco Bay to a mix of tidal marsh, mudflat, managed pond, open water, and other wetland habitats. The goals of the SBSPRP include restoring and enhancing the tidal marsh ecosystem and providing adequate pond habitat to migratory birds (U.S. Fish and Wildlife Service, 2012).

Urban Development Because the Refuge is surrounded by urban development, development projects have a high likelihood of reducing the added biological benefits that habitat restoration projects previously described will provide. Development projects surrounding the Refuge will potentially disturb wildlife resources and have negative impacts on native habitats. Additional restoration activities will likely be needed to offset the future loss of open space to commercial and residential developments (U.S. Fish and Wildlife Service, 2012).

The San Francisco Estuary Invasive Spartina Project This project was created in 2000 by the California State Coastal Conservancy to develop a regionally coordinated project to address the rapid spread of four introduced and highly invasive Spartina (cordgrass) species in the San Francisco Estuary. The Spartina Control Program, the “action arm” of the Spartina Project, was created to arrest and reverse the spread of invasive, non-native cordgrass species in the Estuary to preserve and restore the ecological integrity of the Estuary’s intertidal habitats and estuarine ecosystem. The Spartina Project is currently working with the Control Program to develop a set of “best practices” for tidal marsh restoration to minimize the risk of spreading invasive Spartina and its hybrids (U.S. Fish and Wildlife Service, 2012).

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 22 Climate Change Cayan et al. (2009) suggest California is expected to be 15 to 35 percent drier by the year 2100. By 2050, California is projected to warm by approximately 2.7°F average annual temperature above 2000 averages, a threefold increase in the rate of warming over the last century.

Such climate stressors (e.g., increased temperatures and seal level rise) are expected to affect tidal flats and open water via declining estuarine food web productivity, algal blooms, increased salinity, disease, and loss of tidal flat habitat from sea-level rise. These changes would likely result in impacts to native fish populations and waterbird species’ distributions (California Landscape Conservation Cooperative, et al., 2018).

Sea level rise could also outpace sediment accretion and tectonic uplift, resulting in inundating tidal marshes for longer periods of time. This increased inundation ultimately decreases plant production and increases compaction and decomposition or can lead to anoxic soils. Eventually, high rates of sea-level rise will lead to the conversion of marsh to mudflats and the possible expansion of marsh into upland areas. This process will likely result in changes in vegetation and habitat availability for marsh-dependent species such as the California Ridgway’s rail, salt marsh harvest mouse, common yellowthroat, and song sparrow (California Landscape Conservation Cooperative, et al., 2018; Takekawa, et al., 2013).

Environmental Consequences

Alternative A — No Action Hunting on the Refuge has several potential impacts on vegetation and habitat via trampling of vegetation when retrieving downed birds or unauthorized human access. Such trampling, especially in fragile tidal marsh habitat, could lower the quality of marsh habitat and/or create trails for mammalian predators. Invasive species or “invasive hitchhikers” can also be introduced by hunters’ boots or equipment, or in the case of aquatic nuisance species, by boats. If an introduced invasive species succeeds in its new environment, it can out-compete native plants and ultimately displace entire communities of plants and associated wildlife.

Such impacts to Refuge vegetation, however, are expected to be minimal. Hunting is permitted on foot and by boat, but because the hunter population is relatively small, impacts to vegetation from this type of use are expected to be minimal. In 2019, there was an average of 3,500 hunt visits on 10,000 acres of Refuge open to hunting, which provides ample hunt acreage per hunt visit (U.S. Fish and Wildlife Service, n.d.).

Access to hunt areas primarily takes place via existing levees, further minimizing disturbance to wetland areas. Also, the use of hunt blinds deters hunters from disturbing vegetated areas. Because dogs may cause disturbance to wildlife, hunting in tidal areas is restricted to boats only, and hunters must have command of dogs at all times.

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 23 Alternative B — Proposed Action The opening of an additional 960 acres of waterfowl hunting may cause additional trampling of vegetation by foot and by boat, as well as increase the likelihood for invasive species introductions. However, as described under Alternative A, these impacts are expected to be minimal as the hunt acreage per hunt visit is large enough to accommodate 3,500 hunt visits (Olson, 2020).

VISITOR USE AND EXPERIENCE Affected Environment Description of Relevant General Features of Affected Environment According to the Refuge Annual Performance Plan, there were an estimated 770,000 visitors to the Refuge in 2019 (U.S. Fish and Wildlife Service, n.d.). There are opportunities for Refuge visitors to engage in all six of the priority public uses: hunting, fishing, interpretation, environmental education, wildlife observation, and wildlife photography. The Refuge supports these uses through a variety of self-guided and guided opportunities designed to foster an appreciation of Refuge resources, to encourage environmental stewardship, and to inform visitors of the Refuge’s purpose. More details about each of the six priority uses on the Refuge are described in Section 4.12 of the Final CCP/EA (U.S. Fish and Wildlife Service, 2012).

Description of Relevant Environmental Trends and Planned Actions According to the Final CCP/EA, it is estimated that visitor use opportunities will increase by 33 percent on the Refuge by 2027 (U.S. Fish and Wildlife Service, 2012). The increased visitor uses of hiking, bicycling, boating, guided tours, and environmental education programs combined would add more visits to the Refuge, which could result in increased disturbance to wildlife and degradation of habitat. This increased visitation can be attributed to the ongoing San Francisco Bay Trail and Bay Area Water Trail (administered by the Association of Bay Area Governments) projects, as well as the Salt Pond Restoration Project which aims to provide high quality and wildlife-oriented public access and recreation.

Environmental Consequences Description of Affected Resource Alternative A — No Action There were an estimated 770,000 visits to the Refuge in 2019 and 3,500 visits by waterfowl hunters that same year (U.S. Fish and Wildlife Service, n.d.). Without the expansion of 960-acres to the hunt program, no additional impacts on visitor use and experience are expected under this alternative.

Alternative B — Proposed Action Adding 960 acres of hunting would further improve the public uses already available on the Refuge.

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 24 Potential user conflicts between hunting and other refuge uses will be minimized by refuge regulations, wildlife sanctuaries, and non-hunt areas that are available year-round for other non- hunting recreational activities. The mitigation measures identified in the Proposed Action will also help to minimize any potential user conflicts. Hunting (especially gunshot noise) can disturb refuge visitors engaged in other wildlife-dependent recreational uses. The Service expects, however, that the effects of hunting activities on other forms of wildlife-dependent recreation and visitor use will be negligible because most of the non-hunting visitation takes place in other units of the Refuge.

The Service has concluded that opening the tidal portion of Greco Island and Pond A6 to waterfowl hunting will not adversely affect the quality of other wildlife-dependent recreational opportunities and visitor use at the Refuge.

CULTURAL RESOURCES Affected Environment Description of Relevant General Features of Affected Environment Within the Refuge, there are numerous sites and objects of historic interest, some of which have not been evaluated for the National Register of Historic Places (NRHP) or been deemed ineligible (see the Final CCP/E for more details) (U.S. Fish and Wildlife Service, 2012). Cultural resources (e.g., Native American middens, historic salt industry infrastructure, Alviso Cannery, and the Town of Drawbridge) have been identified within the boundaries of the Alviso (which includes Pond A6) and the West Bay (which includes Greco Island) management units. No sites within the Refuge are currently listed on the NRHP, although sites in the vicinity of the Refuge are listed or have been deemed eligible for listing on the NRHP. Located near the Alviso Unit are prehistoric sites, midden mounds, occupation sites, and historic ceramic fragments. Many prehistoric sites exist within or near the West Bay Unit. Three sites within the cities of Belmont and Redwood City are known shell middens of some type. The cities of Palo Alto and Mountain View contain numerous prehistoric sites, including occupation sites and midden sites.

However, no identified cultural resources occur within the hunt boundaries of the refuge, nor in the areas of the Proposed Action. It is possible that other cultural resources may be present within the Refuge that have not yet been identified.

Environmental Consequences Impacts on Affected Resource Alternative A Although no cultural resources exist within the boundary of the Refuge hunt program, it is possible that increased visitors will result in increased degradation and/or vandalism to the sites surrounding the Refuge. The excavation, disturbance, collection, or purchase of historical, ethnological, or archaeological specimens or artifacts, or mementos from the Refuge are

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 25 prohibited The Service expects that the potential effects of waterfowl hunters and their hunting- related activities on cultural resources on the Refuge to be negligible.

The Service will continue to comply with Section 106 of the National Historic Preservation Act of 1966, as amended, and the Archaeological Resources Protection Act, which prohibits the disturbance of archaeological or historical sites and the removal of artifacts. Staff will also coordinate with the Service’s Regional Archaeologist to comply with Federal laws relating to cultural resources.

Alternative B The impacts under this alternative are the same as Alternative A. It is expected that visitation on the Refuge will increase under this alternative, and therefore will increase the possibility of degradation to cultural resources surrounding, but not within, the hunt boundaries of the Refuge. However, the Service will continue to comply with relevant Federal laws relating to cultural resources, thus minimizing any potential impacts.

REFUGE MANAGEMENT AND OPERATIONS Land Use on the Refuge Affected Environment Description of Relevant General Features of Affected Environment The Refuge encompasses lands throughout South San Francisco Bay in Alameda, Santa Clara, and San Mateo Counties in California. The lands and waters included within the Refuge consist of portions of the urbanized communities of San Lorenzo, Hayward, Union City, Fremont, Newark, Milpitas, San Jose, Sunnyvale, Mountain View, East Palo Alto, Menlo Park, and Redwood City. The majority of these historical communities have been greatly reduced in size due primarily to land use changes in the South Bay related to the conversion of marshes to other habitats through the construction of levees, the addition of fill material, and the construction of intricate drainage systems. These initial impacts to the South Bay’s natural habitat types allowed for extensive residential development, agricultural use, salt production, and further flood protection construction. South Bay marshes were further significantly modified via diking to retain and concentrate bay water for salt production (U.S. Fish and Wildlife Service, 2012).

Land uses surrounding the West Bay management unit, which includes Greco Island, are in the cities of East Palo Alto, Menlo Park, San Carlos, and Redwood City. These land uses include the Palo Alto Municipal Golf Course, U.S. Highway 101, and two airports: the San Carlos Airport to the west and the Palo Alto Airport to the southeast. Between the Bair Island and Ravenswood areas of the unit is the Port of Redwood City, which provides both commercial and recreational access to the bay. Located in Menlo Park and surrounded by the unit is Bedwell Bayfront Park, a former landfill that was closed and converted to parkland in the 1980s. Toward the northwestern end of the unit is the South Bay System Authority (SBSA) regional wastewater treatment facility, which handles 122 and recycles local wastewater. A major SBSA sewage line passes

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 26 through the Refuge’s Inner Bair Island on the way to their treatment plant. Greco Island is the largest area of relatively undisturbed (only partially diked), historic tidal marsh in the South Bay.

The land surrounding the northeastern area of the Alviso management unit, which includes the Pond A6, from Interstate 880 to Cushing Parkway is under the jurisdiction of the City of Fremont, and most of the property is subject to development under the Industrial Redevelopment Plan (City of Fremont, 2005). Encompassing 3,000 acres, the redevelopment plan was created to improve local Interstate 880 interchanges to encourage new business growth. Properties are currently zoned general or restricted industrial, although the eventual redevelopment goal is to develop a high technology business district and learning center (Redevelopment Agency of the City of Fremont, 1988). Pond A6 is also a part of the now-complete Phase 1 of the South Bay Salt Pond Restoration Project, which included tidal and managed pond habitat restoration and early experiments for adaptive management.

Major regional access to the Alviso Unit is provided by State Route 237, U.S. Highway 101, and Interstate 880. As most of the unit is open to the public for recreational activities (e.g., hiking, hunting, wildlife viewing), there are numerous access points along local roads, although only some are open to vehicle traffic during hunting season.

Description of Relevant Environmental Trends and Planned Actions Environmental Consequences Impacts on Affected Resource

Alternative A There are no anticipated impacts to land use under this alternative. As described in the Final CCP, the Refuge is managed to restore and protect wildlife habitat and provide wildlife- dependent recreation to the public. The Refuge is surrounded by intense urban development, and the hunt program on the refuge is not expected to further contribute to such development. There are, therefore, no anticipated impacts under this alternative.

Alternative B Under this alternative, the Service expects a slight increase in hunt visits to the Refuge. The Service expects, however, that such an increase will have negligible effects on traffic or roads through the Refuge, or on Refuge management and operations.

Administration Affected Environment Description of Relevant General Features of Affected Environment Waterfowl hunting on the Refuge is designed to be administered with minimal Refuge resources. The cost of administering the hunting operations is included in the Refuge’s annual budget. Additionally, the hunt program on the refuge currently supports 10,000 acres of waterfowl hunting and 13,500 hunt visits annually.

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 27 The annual cost of administering the hunt program at the Refuge is approximately $83,170 in administrative staff time,1 $1,000 in facilities (vehicle use), and $5,000 in materials (repairs and improvements to infrastructure). This includes opening all the ponds two weekends before the opening of hunt season and two weekends after the closing of the season to allow hunters to place and retrieve small boats in the ponds and maintain blinds under Refuge Special Use Permits. Staffing activities include law enforcement, sign posting, graveling entrance roads, responding to public inquiries, and issuing Special Use Permits. When possible, the California Waterfowl Association and local hunters partner with Refuge staff to hold organized work parties to assist with blind and boat dock maintenance at the ponds before each hunting season (U.S. Fish and Wildlife Service, 2012). Environmental Consequences Impacts on Affected Resource

Alternative A Existing staff are adequate to offer the hunt program to the public, including enforcing regulations by Refuge law enforcement officers. The annual cost of administering the hunt program, as described above, is $83,170 in administrative staff time, $1,000 in facilities (vehicle use), and $5,000 in materials (repairs and improvements to infrastructure). There are no changes to the hunt program under this alternative; therefore, there no anticipated impacts on administration under this alternative.

Alternative B Opening hunting on pond A6 and the tidal portion of Greco Island is anticipated to have a negligible effect on staff time and funds. Because other parts of Greco Island are already open for waterfowl hunting, and Pond A6 is to be managed similar to existing hunt units of the Refuge, there is no substantial increase in staff time to operate the hunting program in these additional areas. There is ample Refuge staff to offer this hunt expansion to the public.

SOCIOECONOMICS Local and Regional Economies Affected Environment Description of Relevant General Features of Affected Environment The cities surrounding the Refuge have a diverse economic base that includes strong professional and manufacturing sectors (partly due to the proximity to Silicon Valley). Educational services, health care, and social assistance also play a major role in the local industries.

1 Administrative staff time is calculated as 2 percent of the Refuge Manager’s time ($1,960), 30 percent of Wildlife Refuge Specialist’s time ($34,860), 20 percent of Maintenance Worker’s time ($17,540), and 30 percent of Law Enforcement’s time ($28,810). These time allocations were estimated in dollars using annual salaries at the 2020 locality pay of San Jose-San Francisco-Oakland and 30 percent benefits.

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 28 Table 1. Population sizes in Alameda, Santa Clara, and San Mateo counties.

County 2010 Population 2019 Population % Increase in Population (2010-2019)

Alameda 1,512,986 1,671,329 10%

Santa Clara 1,786,040 1,927,852 8%

San Mateo 719,699 766,573 7%

Description of Relevant Environmental Trends and Planned Actions As depicted in table 1 above, there are increasing populations in all three counties that overlap with the South Bay. As such, impacts on the economy and other social factors like Refuge visitation and traffic will be exacerbated by increased populations.

Environmental Consequences Impacts on Affected Resource

Alternative A This alternative would not open hunting on Pond A6 and the tidal portion of Greco Island, so no increase in hunt visitation on the Refuge is expected. As such, there are no anticipated impacts to local and regional economies under this alternative.

Alternative B Tourism revenue is potentially generated through various activities held at the Refuge, such as guided walks and special events. If an increase in visits to the Refuge occurs under the 960-acre hunt expansion in this alternative, there could be a benefit to the local economy and employment if visitors utilize local businesses such as gas stations, markets, and restaurants. However, since hunting is dispersed and seasonal, this alternative is expected to have a negligible contribution to the local economy.

Environmental Justice Affected Environment Description of Relevant General Features of Affected Environment The following is data from the Service’s 2020 socioeconomic profile reports based on credible public data sources such as the U.S. Bureaus of Labor Statistics and Census, and U.S. Departments of the Interior and Agriculture ([https://headwaterseconomics.org/tools/usfws- indicators/]). In 2018, the median household income for the three counties of Santa Clara, Alameda, and San Mateo were $116,178, $92,574, and $113,776, respectively; this is well above that for the state of California ($71,228). Averaging across these three counties, the median age in 2018 was 38 years old, the same as the U.S. median age (compared to 36 years for the state of

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 29 California). Averaged across the three counties, about 5.5 percent of families live below poverty level in 2018, lower than for California and the U.S. (both about 10 percent). Race and ethnicity distributions across the three counties are in the tables below.

Table 2. Race and Ethnicity across Santa Clara, Alameda, and San Mateo Counties in 2018.

Race and Ethnicity, Percent of Total: Percent of Total: Percent of Total: Percent of Total: 2018 Santa Clara Alameda County San Mateo County Combined County Counties White alone 45.0% 41.5% 51.1% 44.7% Black or African 2.5% 10.8% 2.3% 5.6% American alone American Indian 0.5% 0.7% 0.4% 0.5% alone Asian alone 35.9% 29.6% 28.1% 32.1% Native Hawaii & 0.4% 0.8% 1.4% 0.7% Other Pacific Is. alone Some other race 10.7% 10.3% 11.2% 10.7% alone Two or more races 5.0% 6.3% 5.6% 5.6%

Table 3. Hispanic and Latino populations in Santa Clara, Alameda, and San Mateo Counties in 2018.

Race and Ethnicity, Percent of Total: Percent of Total: Percent of Total: Percent of Total: 2018 Santa Clara County Alameda County San Mateo Combined County Counties Hispanic or Latino 25.80% 22.50% 24.70% 24.30% (of any race) Not Hispanic or 74.20% 77.50% 75.30% 75.70% Latino

Table 4. Percent of minority populations in Santa Clara, Alameda, and San Mateo Counties in 2018.

Race and Ethnicity, 2018 Percent of Total: Percent of Percent of Total: Percent of Total: Santa Clara Total: San Mateo Combined County Alameda County Counties County Total Minority Population 68.00% 68.20% 60.40% 66.70%

The mission of the Service is to work with others to conserve, protect, and enhance fish and wildlife and their habitats for the continuing benefit of the American people. The developing environmental justice strategy of the Service extends this mission by ensuring that all segments of the human population have equal access to America’s fish and wildlife resources and equal access to information that will enable them to participate meaningfully in activities and policy shaping.

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 30 Environmental Consequences

Alternative A The Service has not identified any potential high and adverse environmental or human health impacts from administering the waterfowl hunt program on the Refuge. The median incomes of Santa Clara, Alameda, and San Mateo counties are higher than that of California and the United States. The percent of families living below the poverty level in those three counties is lower than that of California and the United States. As such, the Service has not identified any potential impacts on minority or low-income communities within the impact area.

Alternative B The effects of Alternative B would be the same as Alternative A; minority or low-income communities will not be disproportionately affected by impacts from the action alternative. Monitoring The Refuge System Administration Act mandates the Secretary of the Interior in administering the System to (16 U.S.C. 668dd (a) (4)), monitor the status and trends of fish, wildlife, and plants in each refuge, among other mandates. Additionally, refuge law enforcement officers monitoring hunter density would provide the Refuge Manager with information to determine unsafe conditions. Population monitoring is reviewed annually with the California Department of Fish and Wildlife to ensure that harvest from hunting is not unacceptably impacting the targeted populations. If needed, hunting opportunities will be modified accordingly. Summary of Analysis

ALTERNATIVE A – NO ACTION ALTERNATIVE As described above, under the No Action Alternative, the Service would not open additional areas of the Don Edwards San Francisco Bay NWR to waterfowl hunting opportunities. No changes would be made to wildlife-dependent recreation that currently occurs on the refuge. This alternative does not meet the purpose and needs of the Service as described above.

ALTERNATIVE B – PROPOSED ACTION ALTERNATIVE As described above, the Proposed Action would have minor effects on biological resources and not adversely affect other recreational uses on the Refuge. As described in the Alternatives section above, mitigation measures would ensure that this alternative could be carried out with minimal impacts on biological resources. Additionally, hunting would occur in accordance with state and Federal hunting regulations and would have negligible impacts on staff time and Refuge budget. The Proposed Action would not affect other wildlife-dependent recreation because they can continue to occur during hunting seasons and in the hunt and non-hunt areas. This alternative helps meet the purpose and needs of the Service as described above because it provides additional wildlife-dependent recreation opportunities on the refuge. The Proposed

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 31 Action offers increased public hunting opportunities and fulfills the Service’s mandate under the NWRS Improvement Act. The Service has determined that the Hunt Plan (U.S. Fish and Wildlife Service, 2021a) is compatible with the purposes of Don Edwards San Francisco Bay NWR and the mission of the NWRS, and meets the Service’s priorities and mandates as outlined by the NWRSAA (16 U.S.C. 668dd(a)(4)). The Proposed Action is consistent with and supports the Refuge’s CCP (U.S. Fish and Wildlife Service, 2012).

This alternative helps meet the purpose and needs of the Service as described above because it would provide additional wildlife-dependent recreation opportunities. The Service has determined that the Proposed Action is compatible with the purposes of Don Edwards San Francisco Bay NWR and the mission of the NWRS. List of Preparers Ally Overbay, Natural Resources Division, California-Great Basin Region, DOI Unified Regions 8 and 10, U.S. Fish and Wildlife Service Matthew Brown, Refuge Manager, Don Edwards San Francisco Bay NWR, U.S. Fish and Wildlife Service Chris Barr, Acting Project Leader, San Francisco Bay NWR Complex, U.S. Fish and Wildlife Service Consultation and Coordination

STATE COORDINATION National Wildlife Refuges, including Don Edwards San Francisco Bay National Wildlife Refuge, conduct hunting programs within the framework of state and Federal regulations. All hunts are regulated by the State of California, but the Refuge may elect to be more restrictive to support Refuge management goals.

TRIBAL CONSULTATION The Service has coordinated with tribal representatives to inform them of the proposed rulemaking.

PUBLIC OUTREACH The draft Environmental Assessment will be available to the public and interested agencies for a public review consistent with the publication of the draft 2021–2022 Refuge Specific Regulations for Hunting and Fishing on Regulations.gov. Comments received on the draft document will be considered in the preparation of the Final Environmental Assessment and Hunt Plan.

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Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 33 Gardali, T., Seavy, N. E., DiGaudio, R. T. & Comrack, L. A., 2012. A CLimate Change Vulnerability Assessment of California's At-Risk Birds. PLoS ONE 7(3): e29507.

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Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 34 Moyle, P. B., Kiernan, J. D., Crain, P. K. & Quinones, R. M., 2013. Climate Change Vulnerability of Native and Alien Freswater Fishes of California: A Systematic Assessment Approach. PLoS ONE 8(5): e63883. doi:10.1371/journal.pone.0063883.

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Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 35 Stenzel, L. E., Kjelmyr, J. E., Page, G. W. & Shuford, W. D., 1989. Results of the first comprehensive shorebird census of northern and central California coastal wetlands 8-12 September 1988, Stinson Beach: s.n.

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Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 36 U.S. Fish and Wildlife Service, 2020a. Waterfowl Hunting Information. [Online] Available at: https://www.fws.gov/refuge/Don_Edwards_San_Francisco_Bay/hunting.html

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Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 37 Appendix A

CULTURAL RESOURCES

· Archaeological Resources Protection Act of 1979, 16 U.S.C. 470aa-470mm; 18 CFR Part 1312; 32 CFR Part 229; 36 CFR Part 296; 43 CFR Part 7 · National Historic Preservation Act of 1966, as amended, 16 U.S.C. 470-470x-6; 36 CFR Parts 60, 63, 78, 79, 800, 801, and 810 · Native American Graves Protection and Repatriation Act, 25 U.S.C. 3001-3013; 43 CFR Part 10 · Summary of Compliance: There are no recorded cultural sites within the boundaries of the proposed hunting expansion on Don Edwards San Francisco Bay NWR. The excavation, disturbance, collection, or purchase of historical, ethnological, or archaeological specimens or artifacts, or mementos from the Refuge are prohibited. These protections are noticed to the public in the visitors’ brochures, information kiosks, the Refuge’s webpage, and the Refuge’s Visitor Center. The Service expects that the potential effects waterfowl hunters and their hunting-related activities on cultural resources will be negligible because hunting activities are limited.

FISH AND WILDLIFE

· Endangered Species Act of 1973, as amended, 16 U.S.C. 1531-1544; 36 CFR Part 13; 50 CFR Parts 10, 17, 23, 81, 217, 222, 225, 402, 450 · Summary of compliance: The Service has drafted a Biological Evaluation that addresses potential effects from expanding waterfowl hunting on Greco Island and opening waterfowl hunting on Pond A6 on the following species: California least tern, California Ridgway’s rail, salt marsh harvest mouse, Western snowy plover, North American green sturgeon (Southern Distinct Populations Unit), Steelhead trout (California Central Coast ESU), Palmate-bracted bird’s-beak, point Reyes meadowfoam, Contra Costa goldfields, and California seablite (U.S. Fish and Wildlife Service, 2021b). The Service anticipates that while hunting may affect the California Ridgway’s rail and Steelhead trout, there would be no adverse effects to these species. There are no expected impacts on other listed species.

Environmental Assessment for Expansion of Hunting on Don Edwards San Francisco Bay NWR 38