2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
determination,
the
RWQCB
will
set
specific
requirements
for
needed
upgrades,
expansions,
or
replacement
of
the
existing
landfill
gas
control
system.
The
Burns
&
McDonnell
2005
report
cited
on
page
4.G-13
of
the
Draft
EIR
provided
a
summary
of
existing
soil
data,
which
led
to
additional
investigation
of
soil
and
groundwater
in
2005
and
2006
by
Burns
&
McDonnell.
The
summary
of
the
additional
investigation
is
provided
on
page
4.G-13
of
the
Draft
EIR.
It
is
unclear
what
specific
report
this
comment
is
referencing,
since
there
is
no
Appendix
A-11
to
the
Draft
EIR.
Because
the
Burns
&
McDonnell
2005
report
is
included
in
the
reference
documents
identified
at
the
end
of
Draft
EIR
Section
4.G,
a
copy
of
that
report
is
available
for
review
at
the
City
of
Brisbane
Community
Development
Department,
50
Park
Place,
Brisbane,
California.
The
comment
refers
to
a
statement
on
Page
4.G-13
of
the
Draft
EIR,
discussing
a
Wetland
Mitigation
Plan
that
was
proposed
in
2004,
and
asserts
that
the
studies
for
that
plan
were
minimal.
The
comment
appears
to
assert
that
the
2004
Wetland
Mitigation
Plan
represents
an
unmitigated
impact
of
Project
Site
development.
As
discussed
in
the
,
“Analysis
of
Previous
Actions
That
May
Have
Impacted
Wetlands,”
the
D
raft
EIR
addresses
impacts
of
the
proposed
development
of
the
Baylands
that
would
result
from
the
Project
Site
development
components
discussed
in
Chapter
3,
Project
Description
,
of
the
Draft
EIR.
The
impacts
of
activities
that
occurred
prior
to
the
2010
baseline
do
not
constitute
Project
Site
development
impacts,
and
are
not,
therefore
the
subject
of
this
evaluation.
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
City
of
Brisbane
General
Plan
Section
VII.2,
Open
Space,
Aquatic
Areas,
and
the
Natural
Environment,
does
not
specify
mitigation
ratios
for
impacts
to
wetlands.
Wetland
mitigation
ratios
in
the
Draft
EIR
are
compliant
with
requirements
of
the
“no
net
loss”
of
wetlands
policy
maintained
by
the
Corps
of
Engineers,
RWQCB,
and
California
Department
of
Fish
and
Wildlife,
which
translates
into
a
minimum
1:1
mitigation
ratio.
Brisbane
Baylands
Final
EIR
2.9.1-33
May
2015