2.
Response
to
Comment
2.4
Master
Responses
to
Comments
analysis
in
the
Draft
EIR
required
the
City
to
develop
an
appropriate
threshold
of
significance
to
evaluate
impacts
on
the
windsurfing
area.
The
SFBA’s
comment
letter
did
not
recommend
any
specific
criterion
by
which
to
assess
the
impact
on
the
windsurfing
area.
Under
CEQA,
a
significance
threshold
for
a
given
environmental
effect
represents
the
level
at
which
the
Lead
Agency
finds
the
effects
of
the
project
to
be
significant
13
(CEQA
Guidelines
Section
15064.7).
While
CEQA
encourages
agencies
to
formally
adopt
and
publish
thresholds
of
significance
(see
CEQA
Guidelines
Section
15064.7(a)),
they
are
not
required
to
do
so.
Agencies
have
the
authority
to
determine
the
significance
of
environmental
impacts
on
a
project-by-project
basis.
(
Oakland
Heritage
Alliance
v.
City
of
Oakland
[2011]
195
Cal.App.4th
884,
896.)
The
significance
of
an
environmental
effect
may
be
determined
by
either
a
quantitative
or
qualitative
standard,
or
a
set
of
criteria.
CEQA
Guidelines
Appendix
G
provides
a
list
of
suggested
thresholds
that
agencies
may
use
(although
they
are
not
required
to
do
so)
and,
for
the
most
part,
the
Brisbane
Baylands
Draft
EIR
relies
upon
the
Appendix
G
thresholds
in
its
analysis.
However,
Appendix
G
does
not
include
a
threshold
relevant
to
the
impacts
that
Project
Site
development
might
have
on
windsurfing
resources,
and
it
was
therefore
incumbent
upon
the
City
to
develop
a
threshold
of
significance
to
be
used
in
the
Draft
EIR.
The
City
as
Lead
Agency
considered
the
thresholds
of
significance
used
in
the
few
known
similar
impact
evaluations
under
CEQA
–
namely,
wind
impacts
on
CPSRA
from
the
Executive
Park
project
in
San
Francisco,
and
wind
impacts
on
windsurfing
at
the
Coyote
Point
Recreation
Area
caused
by
waterfront
development
in
Burlingame.
In
these
CEQA
analyses,
the
impact
analysis
methodology
and
the
impact
threshold
of
significance
were
published
in
EIRs
that
were
reviewed
by
the
public
and
then
certified
by
the
Lead
Agency.
Due
to
the
fact
that
the
impact
on
windsurfing
in
CPSRA
from
development
upwind
of
CPSRA
is
an
impact
that
is
common
both
to
the
Brisbane
Baylands
Project
and
to
the
approved
Executive
Park
project,
it
was
determined
that
the
significance
threshold
used
by
the
City
and
County
of
San
Francisco
in
its
CEQA
review
of
the
Executive
Park
project’s
wind
impacts
on
CPSRA
14
would
be
appropriate
for
use
in
evaluating
the
impact
of
the
Brisbane
Baylands
Project.
Therefore,
the
Draft
EIR
(see
page
4.M-10
of
the
Draft
EIR)
uses
the
following
threshold
of
significance
to
evaluate
impacts
on
recreational
windsurfing
by
development
of
the
Baylands:
Baylands
development
would
have
a
significant
impact
on
recreational
windsurfing
resources
if
it
would
substantially
degrade
the
windsurfing
recreational
resource
by
reducing
wind
speeds
“to
the
point
where
the
reductions
would
adversely
affect
windsurfing
in
prime
windsurfing
areas
or
substantially
impair
access
to
prime
windsurfing
areas
from
existing
launch
sites.”
(Draft
EIR
page
4.M
-11)
13
“Significant
effect
on
the
environment”
is
defined
in
the
CEQA
Guidelines
as
“a
substantial,
or
potentially
substantial,
adverse
change
in
any
of
the
physical
conditions
within
the
area
affected
by
the
project,
including
land,
air,
water,
minerals,
flora,
fauna,
ambient
noise,
and
objects
of
historic
or
aesthetic
significance.
An
economic
or
social
change
by
itself
shall
not
be
considered
a
significant
effect
on
the
environment.
A
social
or
economic
change
related
to
a
physical
change
may
be
considered
in
determining
whether
the
physical
change
is
significant.”
14
City
and
County
of
San
Francisco,
Draft
Environmental
Impact
Report,
Executive
Park
Amended
Subarea
Plan
and
the
Yerby
Company
and
Universal
Paragon
Corporation
Development
Projects
(San
Francisco
Case
No.
2006.0422E,
State
Clearinghouse
Number
2006102123),
October
13,
2010.
Brisbane
Baylands
Final
EIR
2.4-91
May
2015