2.
Response
to
Comment
2.4
Master
Responses
to
Comments
conditions
or
climate
change
context
are
not
key
components
of
the
formal
404
delineation
field
effort
or
regulatory
agency
verification
of
wetlands.
By
comparison,
the
surveys
and
analysis
undertaken
for
the
Draft
EIR
provided
for
a
broader
consideration
of
past
conditions
and
resulted
in
a
more
accurate
average
extent
of
wetland
habitats
for
purposes
of
the
Draft
EIR
analysis
compared
to
what
was
included
in
the
2003
wetland
delineation
of
the
Baylands.
Variability
of
Wetland
Expression
within
the
Baylands
In
order
to
reflect
the
concerns
expressed
in
comments
about
wetlands,
and
in
order
to
recognize
variable
wetland
expressions
at
the
Project
Site,
biologists
mapped
the
maximum
and
minimum
expressions
of
wetlands
and
identified
a
midpoint
or
average
wetland
area
over
the
20-year
period
preceding
publication
of
the
Final
EIR.
The
result
of
the
exercise
is
presented
below
and
clearly
demonstrates
that
the
wetland
habitat
boundaries
identified
in
the
Draft
EIR
are
in
line
with
the
20-year
average
wetland
expression
at
the
Baylands.
The
graphic
presented
on
the
following
page
thus
substantiates
the
adequacy
of
the
Draft
EIR
baseline
characterization
of
wetlands
on
the
Baylands.
Based
on
review
of
aerial
imagery,
wetlands
within
the
former
railyard
demonstrate
greater
variability
in
size
depending
on
rainfall
than
other
portions
of
the
Project
Site.
The
wetlands
located
north
of
the
tank
farm
are
also
variable
in
size,
but
not
to
the
same
extent
as
within
the
former
railyard.
The
signatures
associated
with
the
linear
wetland
features
are
more
consistent
and
do
not
vary
significantly
between
year
to
year.
The
signatures
of
wetlands
in
the
“average”
wetland
map
most
closely
matching
those
signatures
are
found
in
Figure
4.C-1.
Recognizing
the
variability
of
wetlands
expression
within
the
Baylands,
a
performance
standard
is
now
included
in
Mitigation
Measure
4.C-
2c.
This
performance
standard
states
that
the
“amount
of
wetlands
impact
that
must
be
mitigated
will
be
determined
by
either
a
404
delineation
wetland,
or
the
wetland
area
identified
in
the
Brisbane
Baylands
Final
EIR,
whichever
is
greater.”
This
performance
standard
would
not
supersede
existing
state
and
federal
regulatory
agency
processes,
conclusions,
or
determinations
of
mitigation
ratios,
but
would
allow
for
mitigation
of
impacts
on
wetland
areas
based
on
a
longer-term
view
than
the
moment
in
time
when
a
formal
wetland
delineation
was
conducted
for
federal
or
state
regulatory
permitting.
This
approach
has
been
selected
because
it
provides
the
opportunity
pursuant
to
CEQA
for
an
inclusive
assessment
of
wetland
habitats
that
is
based
on
science
and
technology,
recognizing
that
wetland
conditions
can
vary
from
year
to
year.
The
outcome
of
the
analysis
according
to
the
performance
standard
set
forth
in
the
Baylands
EIR
may
not
result
in
a
greater
mitigation
ratio,
but
may
result
in
additional
area
mapped
as
wetland
than
might
be
present
at
any
given
point
in
time,
based
on
technical
data.
Brisbane
Baylands
Final
EIR
2.4-26
May
2015