Attachment B 

December 8, 2004

Clyde Morris

Manager, Don Edwards San Francisco Bay National Wildlife Refuge Complex

P. O. Box 524

Newark, CA 94560-0524

Re: Documents for Public Review Concerning Waterfowl Hunting on the Don Edwards San Francisco Bay National Wildlife Refuge

Dear Mr. Morris:

This letter provides comments from the City of Sunnyvale on the three documents for public review concerning waterfowl hunting on the Don Edwards San Francisco Bay National Wildlife Refuge: (1) Amendment to Refuge Hunting Plan for Waterfowl on 5,500 acres of Former Commercial Salt Ponds, (2) draft Environmental Assessment and (3) Compatibility Determination.

The City of Sunnyvale supports the United States Fish and Wildlife Service's plans to develop recreational waterfowl hunting opportunities at the former salt ponds.  Recently adopted legislative policy provides: “Support the provision of waterfowl hunting on the Don Edwards San Francisco Bay National Wildlife Refuge that is in keeping with the safety of the community and the overall goals of the Refuge and the Salt Pond Restoration Project.”  Within the Open Space Sub-Element of Sunnyvale's General Plan, Goal E states that the City will "Encourage and cooperate with other governmental agencies to preserve and protect regional open space and to acquire, develop, maintain and operate regional recreation facilities that are available to people who live, work or visit in Sunnyvale."  Policy E.1 under Goal E states "Support and encourage Santa Clara County, the Midpeninsula Regional Open Space District, State of California, and appropriate federal agencies and established private entities to acquire, develop, maintain and operate existing and new open space and recreational sites and facilities within the urbanized area in and around Sunnyvale."

Because of the nature of this recreational activity, Sunnyvale believes it will be important to adhere to all safety precautions and rules and regulations as outlined in the documents.  Specifically, Sunnyvale believes that the following guidelines and restrictions as set forth in Amendment to Refuge Hunting Plan for Waterfowl On 5,500 Acres of Former Commercial Salt Ponds, will be especially important to implement and enforce for the success of the new Hunting Plan:

          From Section V.B.

·         Hunting would not be allowed from levees.

·         Access would be restricted to use of motor vehicles driven to the small private boats in the ponds

·         Hunting would only be allowed from existing blinds in the ponds

From Section V.C.

·         All applicable State and Federal regulations would be enforced.

·         Hunting dogs would be allowed off leash and under voice control for the purpose of retrieving waterfowl from the ponds.

·         Hunters would be required to keep firearms unloaded until they are within the designated hunt area.

·         Hunting would be permitted only during legal hunting hours (normal hunting hours are usually ½ hour before sunrise to sunset).

·         Refuge would remain closed to all other forms of hunting and target shooting.

·         These areas would be closely monitored to assess if further regulation may be warranted in the future.

From Section V.D.

·         Hunting would be permitted within the framework of applicable State and Federal regulations.  Pre-season meetings between the Refuge and the state to review changes in the regulations and coordinate law enforcement patrol would take place annually.

From Section V.E.

·         The Refuge would maintain an active law enforcement presence by Refuge officers and would coordinate patrols with State game wardens when available to ensure compliance with hunting regulations.

·         The Hunting Program would be monitored by taking information on number of hunters and harvest information conducted by Refuge law enforcement staff. 

·         Enforcement staff would also monitor for compliance with laws and regulations, and impacts to non-huntable wildlife. 

·         Refuge managers would continue to be in contact with local governments adjacent to the proposed hunt areas to determine if there are any conflicts with existing users.

·         Adjustments to the hunt program would be made to correct unanticipated negative impacts.

From Section VI.A.

·         To protect water quality on the ponds, hunters’ boats would be either non motorized or electric motors.  No gas powered motors would be allowed.

From Section VI.C.

·         Under this Amendment, the hunters would not be allowed to drive their vehicles on the levee roads when they are wet enough to cause damage and be unsafe to drive.  The ponds would be closed to hunting on these days.

From Section VII.A.

·         You may possess only approved non-toxic shot while in the field.

·         You must keep firearms unloaded until you are within the designated hunt area.

·         We prohibit target practice on the refuge or any non-hunting discharge of firearms.

The City of Sunnyvale appreciates the opportunity to comment on the proposed Hunting Plan.  If you have any questions, please contact Lorrie Gervin, Environmental Division Manager at (408) 730-7268.

Sincerely,

Dean J. Chu

Mayor