2.
Response
to
Comments
2.8
Individual
Responses
to
Comments
from
Municipalities
proposed
development
in
San
Francisco
and
Daly
City,
along
with
(1)
existing
physical
constraints
limiting
the
ability
to
improve
area
roadways
in
Daly
City
and
San
Francisco
to
achieve
desired
roadway
levels
of
service
and
(2)
Brisbane’s
ina
bility
to
ensure
that
mitigation
measures
calling
for
needed
physical
improvements
to
roadways
outside
of
Brisbane
would,
in
fact,
be
implemented,
there
is
no
amount
of
traffic-generating
development
within
the
Baylands
that
could
be
proposed
without
a
significant
unavoidable
impact
to
roadway
level
of
service
resulting.
A
review
of
Table
4.B-13,
Average
Daily
Operational
Emissions,
indicates
that
a
reduction
of
approximately
87
percent
of
the
amount
of
development
proposed
in
the
DSP
scenario
would
be
necessary
to
reduce
air
pollutant
emissions
from
Baylands
development
to
below
a
level
of
significance.
This
would
translate
to
approximately
580
dwelling
units
and
slightly
over
one
million
square
feet
of
commercial/office
development.
Except
for
the
inclusion
of
residential
use,
which
is
currently
prohibited
by
the
Brisbane
General
Plan
for
the
Baylands,
the
level
of
development
needed
to
eliminate
operational
emissions
of
air
pollutants
is
similar
to
that
proposed
in
the
Renewable
Energy
Alternative
that
is
already
addressed
in
the
Draft
EIR.
The
development
parameters
suggested
in
Comment
would
also
not
eliminate
inconsistency
with
Plan
Bay
Area
projections,
which
do
not
indicate
any
new
housing
within
the
Baylands.
CEQA
Guidelines
Section
15126.6
requires
EIRs
to
describe
a
“range
of
reasonable
alternatives
to
the
project,”
and
states
that
an
EIR
“need
not
consider
every
conceivable
alternative
to
a
project.
Rather
it
must
consider
a
reasonable
range
of
potentially
feasible
alternatives
that
will
foster
informed
decision
making
and
public
participation….”
Furthermore,
an
EIR
need
not
include
multiple
variations
on
the
alternatives
that
it
does
consider.
When
the
relative
advantages
and
disadvantages
of
other
alternatives
can
be
assessed
from
a
review
of
the
alternatives
presented
in
the
EIR,
not
discussing
variations
on
each
theme
is
unnecessary
(i.e.,
alternatives
that
fall
within
the
continuum
discussed
in
the
EIR
need
not
be
described
if
they
can
be
understood
and
considered
by
studying
the
specifics
of
the
alternatives
that
are
discussed).
(
See,
e.g.,
Cherry
Valley
Pass
Acres
&
Neighbors
v.
City
of
Beaumont
(2010)
190
Cal.App.4th
316,
355.)
The
total
amount
of
development
for
the
additional
alternative
suggested
in
Comment
(2.0
to
5.3
million
square
feet
of
building
area)
is
within
the
range
of
alternatives
already
presented
in
the
EIR
by
the
Renewable
Energy
Generation
Alternative
(1.98
million
s.f.
of
building
area),
No
Project-General
Plan
Buildout
Alternative
(2.02
million
s.f.
of
building
area),
Reduced
Intensity
Non-Residential
Alternative
(5.32
million
s.f.
of
building
area),
and
the
Reduced
Intensity
Mixed-Use
Alternative
(6.81
million
s.f.
of
building
area).
In
addition,
the
additional
alternative
suggested
in
Comment
would
represent
Brisbane
Baylands
Final
EIR
2.8.3-10
May
2015