2.
Response
to
Comments
2.10
Individual
Responses
to
Comments
from
Individuals
2.10.16
Linda
Salmon
Because
this
comment
provides
a
summary
conclusion
regarding
the
adequacy
of
the
Draft
EIR
based
on
the
comments
that
follow,
response
is
provided
in
Responses
through
below.
No
factual
evidence
or
specific
references
are
provided
to
support
the
assertions
in
the
comment
related
to
the
inadequacy
of
the
Draft
EIR.
See
1
for
discussion
of
the
use
of
a
Program
EIR.
Nowhere
in
the
Draft
EIR
is
there
any
conclusion
or
implication
that
“no
real
determination
can
be
made”
regarding
impacts
or
mitigation
measures.
For
each
impact
addressed
in
the
Draft
EIR,
a
definitive
conclusion
is
reached
as
to
whether
the
impact
is
less
than
significant,
mitigable,
or
significant
and
unavoidable.
As
discussed
1,
the
Draft
EIR
provides
analysis
and
mitigation
measures
commensurate
with
the
level
of
detail
available
in
the
proposed
Baylands
development
program
and
its
various
components.
Contrary
to
the
assertion
in
the
comment,
the
advantage
of
a
Program
EIR
is
that
proposed
development
can
be
analyzed
and
mitigation
measures
put
in
place
before
site-specific
development
projects
are
proposed,
giving
the
City
a
better
opportunity
to
guide
the
design
of
such
site-specific
development.
The
use
of
a
Program
EIR
also
provides
for
“big
picture”
review
of
proposed
large-scale
development
that
can
be
lost
in
a
Project
EIR
by
requiring
the
overall
effects
of
a
proposed
development
program
be
analyzed
early
in
the
planning
process.
Thus,
use
of
a
program
EIR
provides
the
City
as
lead
agency
with
the
ability
to
proactively
define
the
manner
in
which
development
may
proceed
before
the
City
is
placed
in
the
position
of
having
to
react
to
individual
site-specific
development
proposals.
The
Draft
EIR’s
program-level
analyses
have
led
to
development
of
mitigation
measures
setting
forth
requirements
that
could
result
in
reconfiguration
of
development
and
open
space
preservation
patterns
within
the
Baylands.
For
example,
as
discussed
9,
one
of
the
key
findings
of
the
Draft
EIR
is
that
none
of
the
proposed
concept
plan
scenarios
adequately
provide
for
wildlife
movement
and
habitat
preservation/enhancement,
and
that
reconfiguration
of
development
and
conservation
areas
is
needed
to
mitigate
impacts
of
future
development
under
each
scenario.
Thus,
Mitigation
Measures
4.C-4a
and
4.C-4b
set
forth
performance
standards
to
protect
onsite
resources,
and
require
preparation
and
implementation
of
open
space
and
habitat
protection
plans
that
could
modify
the
overall
pattern
of
developed
and
open
space
land
within
the
Baylands.
Brisbane
Baylands
Final
EIR
2.10.16-1
May
2015