2.
Response
to
Comment
2.4
Master
Responses
to
Comments
environmental
analysis
of
site-specific
development
and
future
implementation
activities
such
as
site
remediation
and
transfer
of
water
supply.
The
analysis
of
Project
impacts
under
CEQA
also
can
promote
environmental
sustainability
by
encouraging
the
incorporation
of
development
standards
and
strategies
into
Project
design,
and
by
requiring
implementation
of
mitigation
measures
that
not
only
avoid
or
minimize
significant
impacts
but
also
promote
the
responsible
use
of
environmental
resources.
Additionally,
the
EIR
analysis
will
allow
for
the
quantification
of
various
environmental
factors
that
contribute
to
environmental
sustainability,
such
as
greenhouse
gas
emissions,
water
usage,
energy
usage
and
generation,
and
solid
waste
generation,
thereby
allowing
the
four
Concept
Plan
scenarios
and
project
alternatives
to
be
compared
according
to
their
relative
performance
in
regard
to
these
various
sustainability
factors.
Use
of
the
Term
“Project”
in
a
Program
EIR
Under
the
CEQA
Guidelines,
the
term
“project”
refers
to
an
activity
subject
to
CEQA
(CEQA
Guidelines
Section
15002(d)).
A
“project”
has
two
essential
elements.
First,
it
is
an
activity
that
may
cause
either
a
direct
(or
reasonably
foreseeable
indirect)
physical
change
in
the
environment.
Second,
it
is
an
activity
directly
undertaken
by
a
public
agency,
an
activity
supported
in
whole
or
in
part
by
a
public
agency;
or
an
activity
involving
the
issuance
by
a
public
agency
of
some
form
of
entitlement,
permit,
or
other
authorization
(Public
Resources
Code
Section
21065;
CEQA
Guidelines
Section
15378).
CEQA’s
definition
of
a
“project”
is
broad
and
includes
the
series
of
related
actions
analyzed
in
a
program
EIR.
The
fact
that
the
Brisbane
Baylands
EIR
uses
the
term
“project”
to
describe
the
related
actions
it
analyzes
does
not
indicate
that
a
project
-
level
of
environmental
analysis
of
a
site
development
has
been
provided.
2.4.2
Master
Response
2:
Role
of
“
Feasibility
”
in
CEQA
Comments
A
number
of
comments
expressed
concer
n
over
the
use
of
the
term
“feasible”
in
the
document,
particularly
in
regard
to
feasibility
of
mitigation
measures.
Response
Defining
Feasibility
Feasibility
has
a
precise
legal
definition
in
CEQA.
CEQA
defines
the
term
“feasible”
as
“capable
of
being
accomplished
in
a
successful
manner
within
a
reasonable
period
of
time,
taking
into
account
economic,
environmental,
social,
and
technological
factors”
(Public
Resources
Code
Section
21061.1).
The
CEQA
Guidelines
add
the
term
“legal”
to
the
list
of
factors
to
take
into
account
(CEQA
Guidelines
Section
15364).
The
concept
of
“feasibility”
is
key
to
determining
which
mitigation
measure(s)
and/or
alternative(s)
must
be
adopted
by
a
Lead
Agency
or
a
Responsible
Agency,
and
which
may
be
rejected.
There
is
no
bright
line
test
for
determining
feasibility
under
CEQA.
As
the
foregoing
Brisbane
Baylands
Final
EIR
2.4-8
May
2015