2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
EIR
is
addition
to
a
review
of
2003
conditions.
See
9
pertaining
to
wetlands
for
a
more
detailed
discussion
of
the
methods
and
approach
to
documenting
wetlands
at
the
Baylands
for
the
Draft
EIR.
The
Draft
EIR
identifies
that
impacts
to
wetlands
would
occur
as
a
result
of
site
remediation
efforts
and
site
build-out.
The
Draft
EIR
concluded
these
impacts
would
be
significant,
as
discussed
in
Impacts
4.C-2
and
4.C-3
(Pages
4.C-47
through
4.C-53).
However,
remediation
of
the
Baylands
Project
Site,
along
with
implementation
of
Mitigation
Measures
4.C-1g,
4.C-2a,
4.C-2b,
4.C-2c,
the
open
space
and
restoration
required
in
Mitigation
Measures
4.C-4a
and
4.C-4b,
and
provision
of
open
space
and
daylighting
of
Visitacion
Creek,
will
create
a
greater
amount
of
wetland/riparian
habitat
and
higher
quality
habitat
than
currently
exists.
See
9,
Identification
of
Wetlands,
for
discussion
regarding
the
extent
of
wetlands
identified
in
the
Draft
EIR.
As
discussed
in
that
Master
Response,
review
of
20
years
of
aerial
photography
confirms
that
the
wetlands
area
identified
in
the
Draft
EIR
is
representative
of
a
20-year
average
condition.
To
the
extent
the
comment
recommends
expanding
wetlands
mitigation,
CEQA
requires
that
mitigation
measures
must
be
“roughly
proportional”
to
the
impacts
of
the
project.
(CEQA
Guidelines
Sec.
15126.4(a)(4)(B).)
The
Draft
EIR
discusses
sea
level
rise
in
Section
4.H,
Surface
Water
Hydrology
and
Water
Quality
,
starting
on
page
4.H-7.
Sea
level
rise
is
anticipated
to
result
in
flooding
in
discrete
locations
at
the
Baylands
and
exacerbate
tidal
conditions
that
restrict
out
flow
from
adjacent
offsite
areas
such
as
the
Levinson
Overflow
Area,
which
is
located
across
Bayshore
Boulevard
from
the
Baylands
Project
site.
Areas
within
and
adjacent
to
the
Brisbane
Baylands
subject
to
sea
level
rise
are
indicated
in
Figure
4.H-4.
The
hydrology
section
of
the
Draft
EIR
also
notes
in
its
sea
level
rise
analysis
that
surface
water
elevations
along
tidally
influenced
areas
would
increase,
which
would
not
reduce
the
function
of
the
tidal
areas,
but
would
likely
result
in
an
increase
in
overall
footprint
of
tidal
areas
compared
with
2010
baseline
conditions.
The
Draft
EIR
states
that
the
general
location
of
the
existing
wetlands
onsite,
including
the
area
proposed
to
be
restored
along
Visitacion
Creek
(i.e.;
daylighting
the
creek
up
to
the
roundhouse
area)
are
at
sufficient
elevation
so
as
not
to
be
threatened
by
rising
tides
and
sea
level.
Pursuant
to
the
requirements
of
CEQA,
the
Draft
EIR
evaluates
changes
to
the
environment
that
would
result
from
proposed
Baylands
development.
Mitigation
Measures
4.H-4a
and
4.H-4b
require
drainage
improvements
for
the
Baylands
Brisbane
Baylands
Final
EIR
2.9.1-16
May
2015