2.
Response
to
Comment
2.4
Master
Responses
to
Comments
2.4.10
Master
Response
10,
Biological
Resources:
Analysis
of
Previous
Actions
That
May
Have
Affected
Wetlands
Comments
A
number
of
comments
referred
to
previous
actions
taken
at
the
Baylands.
Specifically,
comments
referred
to
past
remediation
actions
and
interim
uses
of
the
Project
site
and
expressed
concern
that
the
Draft
EIR
did
not
take
into
consideration
the
detrimental
effects
those
past
actions
may
have
had
on
wetland
resources
within
the
Baylands.
At
least
one
comment
suggested
that
without
considering
past
actions,
the
wetlands
onsite
cannot
be
accurately
represented.
Response
Under
CEQA,
the
proper
baseline
for
analysis
is
existing
conditions,
regardless
of
any
past
actions
that
may
have
occurred
or
affected
the
physical
environmental
prior
to
the
EIR’s
baseline.
It
is
not
the
role
of
an
EIR
being
prepared
pursuant
to
the
provisions
of
CEQA
to
determine
the
nature
or
consequences
of
prior
conduct
or
activities;
the
role
of
the
EIR
is
only
to
analyze
the
physical
environmental
changes
that
will
result
from
implementation
of
the
proposed
project,
to
determine
whether
those
environmental
effects
will
be
significant,
and
to
avoid
or
mitigate
significant
effects
to
the
extent
feasible.
Thus,
comments
regarding
past
actions
within
the
Baylands
and
their
effects
on
biological
resources
do
not
raise
any
significant
environmental
issues
regarding
the
adequacy
of
the
EIR
or
its
analyses
and
conclusions.
The
following
response
is
therefore
provided
for
information
purposes
only.
Representation
of
Wetlands
Existing
information
and
direct
observations
were
used
to
create
a
habitat
map
of
the
Baylands
Project
Site
that
depicts
existing
conditions
in
the
2010
baseline
year.
See
7
for
discussion
of
the
rationale
for
use
of
2010
as
the
baseline
year
and
9
for
discussion
of
the
mapping
of
wetlands
within
the
Project
site.
This
means
that
habitat
characterization
of
the
Project
Site
as
presented
in
Figure
4.C-1
is
based
on
information
gathered
over
a
multi-year
period
by
a
number
of
individuals
and
consulting
firms.
As
part
of
compiling
information
about
the
site
for
the
purposes
of
the
Draft
EIR
analysis,
biologists
reviewed
the
existing
materials
as
a
means
of
understanding
the
site
configurations
and
the
various
descriptions
of
conditions
that
were
then
analyzed
through
direct
field
observation
to
verify
the
extent
of
habitats
present.
The
habitat
map
compiled
in
Figure
4.C-1
of
the
Draft
EIR
was
prepared
to
represent
the
approximate
configuration
of
2010
baseline
year
conditions
within
the
Baylands.
The
impacts
discussed
in
Section
4.C,
Biological
Resources
,
of
the
Draft
EIR
would
occur
as
a
result
of
future
site-specific
development
actions
at
the
Project
Site.
Past
Remediation
Efforts
Previous
actions
at
the
Baylands
mentioned
in
comments
directed
toward
the
analysis
of
biological
resources
focused
on
an
aspect
of
site
remediation
undertaken
pursuant
to
the
Clean
Brisbane
Baylands
Final
EIR
2.4-33
May
2015