2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
A
thermal
oxidizer
is
one
available
mitigation
option
recognized
by
BAAQMD
as
a
method
of
air
quality
and
odor
abatement.
They
are
operated
throughout
the
Bay
Area
for
coffee
roasting
operations
to
abate
odors
and
require
no
permit
but
are
used
to
abate
emissions
from
other
permitted
sources.
Heat
for
thermal
oxidation
is
typically
generated
by
natural
gas
combustion
and
has
emissions
similar
to
that
of
a
small
industrial
boiler
and
would
have
negligible
air
quality
impacts
if
selected
as
an
odor
abatement
device.
There
are
no
policies
of
the
City
of
Brisbane
General
Plan
that
would
preclude
operation
of
a
thermal
oxidation
unit.
The
statement
referred
to
in
Comment
BBCAG-
39
addresses
the
Draft
EIR’s
conclusion
regarding
the
odor
impacts
of
proposed
Baylands
development,
not
to
existing
Baylands
Project
Site
conditions
such
as
algae
blooms
in
the
Brisbane
lagoon.
The
analysis
of
odor
impacts
is
presented
starting
on
page
4.B-45.
The
conclusion
that
proposed
Project
Site
development
would
result
in
less
than
significant
impacts
is
based
on
(1)
the
types
of
uses
proposed
for
the
Baylands
(other
than
the
recycled
water
plant
in
all
scenarios
and
the
Recology
expansion
in
the
CPP-V
scenario),
do
not
typically
emit
obnoxious
odors,
(2)
the
proposed
Recology
expansion
would
be
required
to
meet
BAAQMD
rules
regarding
odors
including
Regulation
(Public
Nuisance)
and
Regulation
7
(Odorous
Substances),
and
(3)
the
proposed
onsite
recycled
water
plant
would
be
required
to
meet
the
odor
detection
thresholds
of
BAAQMD
Regulation
7
(Odorous
Substances).
This
comment
does
not
raise
any
significant
environmental
issues
regarding
the
adequacy
of
the
Draft
EIR
or
its
analyses
and
conclusions.
Section
4.C,
Biological
Resources,
of
the
Draft
EIR
adequately
characterizes
existing
habitats,
including
habitat
for
birds
and
aquatic
species.
This
characterization
is
depicted
in
Figure
4.C-1,
and
formed
the
basis
of
the
Draft
EIR
analysis
of
impacts
to
Baylands
habitats,
including
habitat
for
aquatic
species
and
habitat
used
by
migratory
birds.
Impacts
to
aquatic
habitats
would
primarily
occur
as
a
result
of
site
cleanup
and
remediation
actions
that
will
result
in
significant,
mitigable
impacts,
but
would
have
long
term
benefits
to
aquatic
species
because
the
habitat
will
be
cleaned,
restored,
monitored,
and
managed,
which
is
superior
to
the
existing
conditions
at
the
site.
After
remediation,
Project
Site
development
impacts
to
aquatic
habitats
would
be
less
than
significant.
Aquatic
habitats
in
the
Baylands
are
treated
in
the
Draft
EIR
as
a
sensitive
habitat
type.
A
discussion
of
aquatic
habitats
at
the
Baylands
occurs
on
page
4.C-19,
and
page
4.C-47
introduces
several
mitigation
measures
as
a
means
of
mitigating
impacts
to
sensitive
habitats
including
aquatic
habitats.
Specifically,
Measures
4.C-
Brisbane
Baylands
Final
EIR
2.9.1-13
May
2015