2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
The
Draft
EIR
analyzes
grading
of
the
site
as
it
is
currently
proposed.
Proposed
site
grading
is
intended
to
provide
for
(1)
a
permanent
cover
for
the
former
landfill,
(2)
the
proposed
Geneva
Avenue
extension
and
other
grade-separated
over-crossings
of
the
Caltrain
tracks,
(3)
remediation
of
the
former
railyard,
and
(4)
adequate
site
drainage.
Proposed
site
grading
is
discussed
Chapter
3,
Project
Description
,
which
also
discusses
floodplain
management
criteria
on
page
4.H-8
and
identifies
the
portions
of
the
Project
Site
that
are
at
current
risk
and
a
future
risk
due
to
a
sea
level
rise
of
1.4
meters
in
Figure
4.H-4.
The
Mitigation
Monitoring
and
Report
Plan
set
forth
in
Section
4.0
of
the
Final
EIR
provides
for
enforcement
of
EIR
mitigation
measures,
including
those
concerning
water
quality.
See
3
for
a
discussion
of
the
enforceability
of
the
mitigation
measures
set
forth
in
the
Draft
EIR.
Pages
4.H-12
through
4.H-14
of
the
Draft
EIR
discuss
the
permit
requirements
that
would
apply
to
all
proposed
Project
Site
development
construction
activities.
As
required
by
Mitigation
Measure
4.H-
1a,
“prior
to
issuance
of
a
grading
permit,
an
applicant
for
any
site
specific
development
project
to
be
constructed
within
the
Project
Site
shall
file
a
Notice
of
Intent
to
the
RWQCB
to
comply
with
the
statewide
General
Permit
for
Discharges
of
Storm
Water
Associated
with
Construction
Activities
and
shall
prepare
and
implement
a
SWPPP
for
construction
activities
on
the
Project
Site
in
accordance
with
the
NPDES
General
Construction
Permit
and
the
demonstrate
compliance
with
the
City
of
Brisbane’s
Municipal
Regional
Stormwater
Permit
Order
No.
2011-0083
Provision
C.3.
The
SWPPP
shall
include
all
provisions
of
the
Erosion
and
Sediment
Control
Plan
submitted
as
part
of
grading
and
construction
permits.
In
addition
to
meeting
the
regulatory
requirements
for
the
SWPPP,
the
site-specific
SWPPP
shall
include
provisions
for
the
minimization
of
sediment
disturbance
(i.e.,
production
of
turbidity)
and
release
of
chemicals
to
the
Bay.”
Adherence
to
this
Mitigation
Measure
would
require
the
preparation
and
implementation
of
a
stormwater
pollution
prevention
plan
containing
best
management
practices
including
erosion
control
measures
that
would
minimize
the
transport
of
sediments
offsite.
As
discussed
in
the
Draft
EIR
(p.
4.H-12),
the
monitoring
and
sampling
requirements
imposed
by
the
General
Permit
depend
on
the
final
Risk
Level
category
of
the
site,
which
is
calculated
by
quantifying
(1)
the
risk
that
Project
Site
development
would
produce
sediment
and
(2)
the
sensitivity
of
the
water
features
that
could
receive
sediment
eroded
from
the
Baylands
site.
Adherence
to
the
permit
requirements,
including
water
quality
monitoring
and
sampling
requirements,
would
ensure
that
water
quality
impacts
associated
with
construction
would
be
less
than
significant.
Brisbane
Baylands
Final
EIR
2.9.1-93
May
2015