2.
Response
to
Comment
2.4
Master
Responses
to
Comments
Survey
Timing
Wetlands
in
the
Baylands
have
established
over
time
and
continue
to
change
in
response
to
rainfall
patterns
that
are
critical
to
the
hydrologic
functions
of
these
systems.
The
appearance
year-over-year
of
a
given
wetland
can
vary
depending
on
rainfall
and
duration
of
inundation.
There
are
no
specifications
included
in
the
implementation
methodology
included
in
the
wetland
regulatory
process
described
in
Section
404
of
the
Clean
Water
Act
that
require
wetland
surveys
to
occur
over
multiple
years.
Rather,
the
United
States
Army
Corps
of
Engineers,
which
enforces
the
Clean
Water
Act,
relies
upon
a
three-point
test
(vegetation,
hydrology,
and
soils)
as
a
means
of
determining
the
boundaries
of
a
wetland,
as
at
least
one
or
more
of
the
criteria
are
present
at
all
times
of
year.
2
For
instance,
if
the
wetland
has
completely
dried
out,
examination
of
the
soils
during
summer
months
will
verify
that
wetland
conditions
existed
at
the
site.
Or,
even
if
the
wetland
retains
no
standing
water,
the
vegetation
present
is
an
indicator
that
the
area
is
a
wetland.
The
reconnaissance
surveys
conducted
at
the
Baylands
for
the
Draft
EIR
were
timed
to
maximize
observations
of
all
biological
resources
including
wetlands.
Biologists
surveying
the
site
observed
vegetation,
soils,
and
any
existing
hydrology
and
used
professional
judgment
to
determine
the
extent
of
wetlands
on
the
Baylands.
The
level
of
field
study
and
review
of
existing
data
undertaken
for
the
Draft
EIR
was
thus
sufficient
to
provide
the
basis
for
an
impact
analysis
of
the
four
development
scenarios.
Habitat
Mapping
The
habitat
map
included
in
Draft
EIR
Figure
4.C-1
captures
wetlands
at
the
Baylands
Project
Site.
To
create
Figure
4.C-1
of
the
Draft
EIR,
biologists
reviewed
data
collected
at
the
Project
Site,
including
a
2003
wetland
delineation
produced
by
Burns
and
MacDonald,
among
other
data
sources
identified
as
references
in
the
Draft
EIR,
to
augment
direct
observations
made
in
the
field.
Reconnaissance-level
field
surveys
were
undertaken
on
March
2,
2007;
June
20
2007;
April
20,
2011;
and
April
19,
2013.
This
level
of
effort
represents
a
broader
data
set
than
what
would
typically
be
referenced
in
preparing
a
United
States
Army
Corps
of
Engineers
wetland
delineation,
which
would
involve
only
a
site-specific
survey
and
would
not
be
required
to
capture
and
consider
additional
data
from
multiple
sources
over
multiple
years.
In
this
context,
it
is
worth
noting
that
the
extent
of
wetland
habitats
shown
in
Figure
4.C-1
of
the
Final
EIR
is
considerably
greater
than
the
wetland
boundaries
contained
in
the
2003
wetland
delineation
that
is
cited
in
the
Draft
EIR.
This
is
due
to
the
fact
that
wetland
features
are
dynamic
and,
depending
on
the
conditions
of
the
year
and
the
multi-year
rainfall
pattern
in
which
observations
are
made,
the
total
wetland
area
used
for
the
determination
of
impacts
calculations
can
vary.
The
formal
delineation
process
used
by
regulatory
agencies
captures
the
extent
of
wetlands
at
a
specific
moment
in
time,
typically
just
prior
to
project
construction.
Rainfall
2
The
United
States
Fish
and
Wildlife
Service
(USFWS)
and
United
States
Army
Corps
of
Engineers
use
different
definitions
and
methods
to
identify
wetlands.
Although
the
California
Fish
and
Wildlife
Commission
wetland
policy,
which
is
not
a
regulatory
program,
recommends
use
of
the
USFWS
wetland
definition/classification
system,
the
Corps
of
Engineers
definition
was
used
in
the
Draft
EIR
because
(1)
it
is
the
most
biologically
valid
method
to
identify/classify
wetlands,
(2)
Corps
of
Engineers
delineation
methods
are
the
most
conservative
among
the
agencies,
and
(3)
these
methods
are
more
inclusive
and
biologically
broad.
Brisbane
Baylands
Final
EIR
2.4-25
May
2015