Final Mitigated Negative Declaration and Response to Comments

LAHONTAN REGIONAL WATER QUALITY CONTROL BOARD (LRWQCB) RESPONSE
GENERAL COMMENT ON PREPARATION OF A HACCP
Preparation of a Hazard Analysis and Critical Control Point (HACCP) plan should be an
element of risk management that is built into the project.
RESPONSE
Mitigation Measure Hydro-1: Water Quality states that underwater AC control activities in
Lake Tahoe require permits from the Army Corps of Engineers, Lahontan Regional Water
Quality Control Board, Tahoe Regional Planning Agency, and the California Department of
Fish and Game. All of these permits require monitoring and protective measures to ensure
that project activities do not result in significant impacts to water quality. Project activities will
not commence until all required permits are attained.
To prevent impacts to Lake Tahoe from inadvertent movement or introduction of non-target
species, regulatory agencies in the Lake Tahoe basin are now requiring preparation and
adherence to a Hazard Analysis and Critical Control Point (HACCP) plan. HACCP planning is
an international standard for reducing or eliminating the spread of unwanted species during
specific processes or practices, such as delivery, removal, and installation of benthic barriers.
The Water Quality Control Plan for the Lahontan Region (LRWQCB 1994 Chapter 5: Water
Quality Standards and Control Measures for the Lake Tahoe Basin) has designated beneficial
uses for the surface waters of the Lake Tahoe Hydrologic Unit, such as Cold Freshwater
Habitat. HACCP planning will be a permit requirement of this project and this planning will help
protect these beneficial uses.
COMMENTS ON PROJECT DESCRIPTION AND IMPLEMENTATION, SECTION 2.5
WEED FREE STRAW COMMENT
The IS/MND explains that one alternative method involves the placement of straw (organic
matter) under the barriers. If this method is used, the organic matter (straw) that is used must
be certified weed free to eliminate the introduction of potential non-native and invasive weeds.
The use of certified weed free straw should be identified as a control measure in the HACCP
(detailed above).
RESPONSE
The HACCP developed as a permit requirement for restoration work in Lake Tahoe to control
Asian clams (see response above) will require the use of certified weed free straw if organic
matter is used to augment benthic barriers. Mitigation Measure Hydro-1 requires that project
activities attain permits from regulatory agencies in the basin and this requirement of use of
weed free straw or other organic matter will be a condition of this mitigation measure.
FREEZING CLAMS COMMENT
More detail is required for the LRWQCB to assess potential impacts of pilot testing of
technology to freeze clams in place in the lake sediment.
RESPONSE
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Asian Clam Control Project
Final Mitigated Negative Declaration and Response to Comments