2.
Response
to
Comments
2.10
Individual
Responses
to
Comments
from
Individuals
The
comment
addresses
proposed
development
within
the
Baylands
and
does
not
raise
any
significant
environmental
issues
regarding
the
Draft
EIR
or
its
analysis
and
conclusions.
The
City
will
consider
the
concerns
and
conclusions
raised
in
the
comment
as
part
of
its
planning
review
and
decision
making.
The
assessment
of
air
quality
impacts
in
the
Draft
EIR
does
not
assess
impacts
on
a
per
capita
basis.
Rather,
criteria
air
pollutant
impacts
are
assessed
relative
to
mass
emission
thresholds
in
terms
of
pounds
per
day
and
tons
per
year
for
a
given
pollutant
or
precursor.
Increased
cancer
risk
and
hazard
impacts
are
assessed
relative
to
an
increased
cancer
risk
threshold
of
10
in
one
million,
while
localized
particulate
impacts
are
assessed
relative
to
an
ambient
concentration
threshold
of
0.3
micrograms
per
cubic
meter.
The
analysis
of
greenhouse
gas-related
impacts
utilizes
a
significance
threshold
that
is
based
on
service
population
(the
combination
of
residents
and
employees
of
a
given
mixed
use
development
project).
BAAQMD
indicates
its
intent
to
have
the
efficiency
threshold
apply
to
specific
plans
in
Table
2-5,
Thresholds
of
Significance
for
Plans,
in
its
2011
CEQA
Air
Quality
Guidelines,
which
specifically
states
that
specific
plans
should
use
the
project-level
threshold
of
4.6
CO2e
per
service
population
per
year.
The
BAAQMD
has
identified
a
potential
bright-line
threshold
of
1,100
metric
tons
per
year
of
CO2e
as
discussed
on
page
4.F-12
of
the
Draft
EIR.
As
a
practical
matter,
this
threshold
is
relatively
stringent
and
is
exceeded
by
most
development
projects
of
more
than
500
residential
units
or
100,000
square
feet
of
retail
or
350,000
square
feet
of
office.
In
an
effort
to
encourage
mixed-use
development,
focus
on
the
efficiency
of
proposed
development,
and
provide
for
analysis
and
mitigation
of
numerous
smaller
development
projects,
BAAQMD
identified
the
service
population
1
-based
efficiency
threshold
used
in
this
analysis,
which
is
more
applicable
to
assessing
the
impacts
of
a
Specific
Plan.
BAAQMD
indicates
its
intent
to
have
the
efficiency
threshold
apply
to
Specific
Plans
in
Table
2-5,
Thresholds
of
Significance
for
Plans,
in
its
2011
CEQA
Air
Quality
Guidelines,
which
specifically
states
that
specific
plans
should
use
the
project-
level
threshold
of
4.6
CO2e
per
service
population
per
year.
See
regarding
responsibilities
for
construction/maintenance
of
needed
infrastructure,
including
responsibilities
for
financing.
1
“Service
Population”
(SP)
is
an
efficiency-based
measure
used
by
BAAQMD
to
estimate
the
development
potential
of
a
general
or
area
plan.
SP
is
determined
by
adding
the
number
of
residents
to
the
number
of
jobs
estimated
for
a
given
point
in
time.
Brisbane
Baylands
Final
EIR
2.10.19-3
May
2015