2.
Response
to
Comment
2.4
Master
Responses
to
Comments
habitats.
In
addition,
terms
and
conditions
of
project
implementation
would
be
stipulated
in
regulatory
permits
for
subsequent
projects
(e.g.,
a
Section
404
permit
or
lake
and
streambed
alteration
agreement).
In
addition
to
the
requirements
of
the
Baylands
EIR,
site-specific
development
would
be
subject
to
approval
by
state
and
federal
regulatory
agencies
(e.g.,
California
Department
of
Fish
and
Wildlife,
United
States
Fish
and
Wildlife
Service,
National
Marine
Fisheries
Service,
and
United
States
Army
Corps
of
Engineers)
prior
to
start
of
construction.
2.4.9
Master
Response
9,
Biological
Resources:
Identification
of
Wetlands
Comments
A
number
of
comments
were
submitted
in
relation
to
wetland
areas
within
the
Baylands
Project
Site.
These
comments
raised
questions
regarding
the
methodology
and
timing
of
biological
resources
surveys
that
were
undertaken
for
the
Draft
EIR,
along
with
concerns
that
the
Draft
EIR
did
not
account
for
all
of
the
wetland
areas
that
comment
writers
believed
to
be
present
within
the
Baylands.
Response
Study
Methods
The
biological
resources
analysis
included
in
the
Draft
EIR
was
developed
using
2010
as
the
baseline
year,
meaning
that
the
analysis
was
based
on
conditions
as
they
existed
within
the
Baylands
in
the
year
2010.
(Please
see
Master Response
7
for
a
discussion
of
the
rationale
for
the
2010
base
year
used
in
the
Draft
EIR.)
The
biological
resources
analysis
and
presentation
of
wetlands
habitats,
impacts,
and
mitigation
in
the
Draft
EIR
are
habitat-based,
analyze
impacts
at
a
program
level,
and
set
the
parameters
for
addressing
impacts
on
biological
resources,
including
performance
standards
for
wetlands
mitigation
as
the
Baylands
Project
Site
is
developed
over
a
projected
20-year
period.
Developing
a
more
detailed
presentation
of
setting
and
impacts,
beyond
a
habitat-based
level
of
detail,
is
not
feasible
for
a
programmatic
EIR
where
the
final
development
is
not
fully
designed.
During
subsequent
environmental
review
of
site-specific
development
within
the
Baylands,
the
impacts
of
development
on
wetlands
would
be
analyzed
in
greater
detail
based
on
the
precise
location
of
proposed
grading,
buildings,
roadways,
and
other
areas
of
ground
disturbance.
This
means
that
the
details
of
the
development
footprint,
construction
methods
and
duration,
and
the
proposed
operation
of
each
proposed
development
would
be
defined
in
much
greater
detail
than
is
available
in
the
concept
scenarios,
thereby
allowing
for
an
increased
level
of
detail
in
the
impacts
analysis
of
future,
site-specific
development.
Brisbane
Baylands
Final
EIR
2.4-24
May
2015
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