2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
require
non-reflective
coatings
and
surfaces
for
buildings
greater
than
100
feet
tall
as
a
means
of
minimizing
disturbance
to
migrating
birds
during
night
migration.
CEQA
requires
that
the
impacts
of
a
project
be
evaluated
by
analyzing
the
changes
that
would
occur
from
baseline
conditions
should
the
proposed
project
be
implemented.
The
Draft
EIR
discussion
of
baseline
conditions
is
based
on
field
surveys,
literature,
and
data
base
review,
and
professional
judgment
of
qualified
biologists,
and
adequately
describes
baseline
conditions.
As
discussed
7,
the
baseline
year
for
the
Brisbane
Baylands
is
2010.
Thus,
the
Draft
EIR
examines
the
changes
that
would
occur
compared
to
2010
conditions
should
any
of
the
concept
plan
scenarios
be
selected
and
developed.
As
discussed
9,
analysis
of
wetland
conditions
based
on
a
review
of
twenty
years
of
aerial
photographs
demonstrated
that
the
extent
of
wetland
within
the
Baylands
has
varied
considerably
over
the
past
20
years,
and
also
confirmed
that
the
2010
baseline
condition
used
in
the
Draft
EIR
(Figure
4.C-1)
exceed
by
approximately
20
percent
th
e
“average”
wetland
expression
(total
area)
observable
over
the
past
20-year
period.
The
graphic
results
of
this
20-year
review
of
air
photo
data
of
wetland
area
within
the
Baylands
is
presented
9,
confirming
the
adequacy
of
the
Draft
EIR’s
characterization
of
baseline
wetlands
within
the
Baylands.
Recognizing
the
year
to
year
variability
of
wetland
area
within
the
Baylands,
Mitigation
Measure
4.C-2c
has
been
modified
7
to
require
mitigation
of
wetlands
impacts
based
on
either
(1)
the
wetland
area
identified
in
the
Brisbane
Baylands
EIR
(which
is
indicative
of
the
“average”
wetland
expression
within
the
Baylands)
or
(2)
a
current
wetlands
delineation,
whichever
is
greater.
Baseline
conditions
were
determined
using
various
data
sources
and
direct
observations
in
addition
to
information
from
the
2003
wetland
delineation.
Results
are
shown
in
Figure
4.C-1.
These
reconnaissance
level
surveys,
rather
than
a
formal
wetland
delineation,
confirmed
the
general
boundaries
of
habitats,
including
wetland
habitats.
The
months
that
occur
during
the
spring
season,
including
March
and
April,
generally
represent
the
appropriate
timing
that
would
maximize
opportunities
to
observe
site
conditions
across
multiple
habitat
types
during
a
site
characterization
effort.
As
discussed
in
Section
4.C
on
page
4.C-2,
reconnaissance
surveys
were
conducted
in
2007,
2011
and
2013
during
the
months
of
March
and
April
to
establish
baseline
conditions
for
EIR
analysis.
These
reconnaissance
surveys
considered
wetlands
in
addition
to
other
habitat
types
present
within
the
Baylands.
Direct
observations
of
wetlands
in
2007,
2011,
and
2013
were
considered
in
the
Draft
7
The
modified
mitigation
measure
can
be
found
as
part
of
9,
Identification
of
Wetlands.
Brisbane
Baylands
Final
EIR
2.9.1-15
May
2015