2.
Response
to
Comment
2.4
Master
Responses
to
Comments
Plan
be
deemed
an
application
for
any
form
of
development
project
approval
under
the
City’s
subdivision
or
Zoning
regulations.”
Thus,
the
Concept
Plan
required
by
General
Plan
policy
is
just
that
–
a
concept
–
and
is
not
an
application
for
a
specific
development.
The
Concept
Plans
for
the
DSP,
DSP-V,
CPP,
and
CPP-V
scenarios
are
included
in
the
Draft
EIR,
Section
3.5
(
Concept
Plan
Development
Scenarios
)
starting
on
page
Program-Level
Analysis
under
CEQA
As
described
starting
on
page
of
the
Draft
EIR,
CEQA
Guidelines
Section
15168(a)
states
that
a
single
program
EIR
may
be
prepared
to
address
a
series
of
actions
that
“are
related
either:
(1)
(2)
(3)
(4)
Geographically,
As
logical
parts
in
the
chain
of
contemplated
actions,
In
connection
with
issuance
of
rules,
regulations,
plans,
or
other
general
criteria
to
govern
the
conduct
of
a
continuing
program,
or
As
individual
activities
carried
out
under
the
same
authorizing
statutory
or
regulatory
authority
and
having
generally
similar
environmental
effects
which
can
be
mitigated
in
similar
ways.”
An
advantage
of
a
program
EIR
is
that
it
allows
the
Lead
Agency
(here
the
City
of
Brisbane)
to
“consider
broad
policy
alternatives
and
program
wide
mitigation
mea
sures
at
an
early
time
when
the
agency
has
greater
flexibility
to
deal
with
basic
problems
or
cumulative
impacts”
(CEQA
Guidelines
Section
15168(b)(4)).
To
address
a
common
misunderstanding,
this
program
EIR
does
not
evaluate
site-specific
development
within
the
Baylands,
and
the
City
may
not
approve
site-specific
development
by
relying
solely
on
this
EIR.
Prior
to
approving
any
site-specific
development,
the
City
must
conduct
further
environmental
review
under
CEQA.
Consistent
with
CEQA’s
requirements,
th
e
specificity
of
the
program-level
analysis
in
the
EIR
corresponds
to
the
level
of
detail
that
is
currently
available
for
the
Baylands
Project
components.
(See
CEQA
Guidelines
Section
15146.)
Until
specific
development
projects
are
actually
proposed
through
subdivision
maps,
conditional
use
permits,
site
development
permits,
or
similar
actions,
project-level
analysis
would
be
speculative
and
therefore
is
not
required
under
CEQA.
The
program-level
analysis
provided
in
the
Draft
EIR
allows
for
early
and
more
comprehensive
evaluation
of
all
elements
of
proposed
Baylands
development,
and
enables
the
City
to
establish
mitigation
requirements
for
such
development
before
detailed
site
planning,
engineering,
and
design
are
undertaken.
By
providing
the
public,
the
City,
and
other
permitting
agencies
with
an
opportunity
to
review
and
consider
the
reasonably
foreseeable
environmental
impacts
of
the
development
of
the
Baylands
as
a
whole,
prior
to
City
Council
decisions
on
any
portion
of
the
site
development,
the
EIR
is
fulfilling
two
mandated
goals
of
the
CEQA
process:
(1)
providing
for
environmental
review
and
long-range
disclosure
of
impacts
and
required
mitigation
at
the
earliest
feasible
time,
and
(2)
avoiding
“piecemeal”
review
that
could
underestimate
the
combined
environmental
impacts
of
a
development
program
as
large
and
complex
as
the
Brisbane
Baylands.
Brisbane
Baylands
Final
EIR
2.4-4
May
2015