2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
The
method
for
selection
of
BMPs
with
agency
review
as
to
whether
specified
goals
will
be
met
is
the
commonly
accepted
method
for
implementing
performance-based
mitigation
measures.
See
3
regarding
implementation
of
EIR
mitigation
measures.
In
addition,
as
required
by
Mitigation
Measure
4.H-1c
on
page
4.H-24
of
the
Draft
EIR,
all
Project
Site
de
velopment
shall
“prepare
and
implement
a
Final
Stormwater
Management
Plan
(SMP)
in
accordance
with
the
most
recent
NPDES
C.3
requirements.”
The
measure
goes
on
to
require
that
the
SMP
“shall
provide
operations
and
maintenance
guidelines
for
all
of
the
BMPs
identified
in
the
SMP,
including
LID
measures
and
other
BMPs
designed
to
mitigate
potential
water
quality
degradation
of
runoff
from
all
portions
of
the
completed
development.”
Draft
EIR
page
4.H-23
describes
examples
of
the
treatment
measures
that
“would
vary
from
‘local’
improvements
at
individual
building
sites
to
‘areawide’
concepts
such
as
stormwater
treatment
wetlands
with
large
open
space
areas.
The
treatment
BMPs
would
be
required
to
include
one
or
more
of
the
following:
bioretention
areas
(including
bioretention
swales),
flow-through
planters,
tree
well
filters,
vegetated
buffer
strips,
infiltration
trenches,
extended
detention
basins,
pervious
paving,
green
roofs,
and
media
filter.”
With
implementation
of
these
treatment
BMPs,
the
Project
would
be
in
compliance
with
BCDC
Water
Quality
Policy
7
which
calls
for
native
vegetation
buffer
areas,
whenever
practicable,
to
be
part
of
a
project
to
control
pollutants
from
entering
the
Bay.
Mitigation
Measure
4.H-1c
requires
all
“Applicants
for
site
-specific
development
projects
to
be
constructed
within
the
Project
Site
shall
prepare
and
implement
a
Final
Stormwater
Management
Plan
(SMP)
in
accordance
with
the
most
recent
NPDES
C.3
requirements.”
The
Mitigati
on
Measure
also
requires
that
the
“SMP
shall
provide
operations
and
maintenance
guidelines
for
all
of
the
BMPs
identified
in
the
SMP,
including
LID
measures
and
other
BMPs
designed
to
mitigate
potential
water
quality
degradation
of
runoff
from
all
portions
of
the
completed
development.”
See
Draft
EIR
pages
4.H-22
and
4.H-23
for
a
discussion
of
LID
measures
typically
used
to
comply
with
Provision
C.3
requirements.
Compliance
with
the
stormwater
management
plan,
including
LID
measures,
would
ensure
that
operation
of
site
specific
development
on
the
Baylands
Project
Site
would
result
in
less
than
significant
impacts
to
water
quality
and
would
not
violate
waste
discharge
requirements.
There
is
no
factual
basis
provided
in
the
comment
to
support
its
assertion
that
the
city’s
current
storm
drainage
master
plan
is
inadequate.
Storm
drainage
infrastructure
to
be
developed
for
the
Baylands
will
be
required
to
be
in
compliance
with
all
applicable
regulatory
requirements
in
place
at
the
time
construction
plans
are
approved,
and
will
be
required
to
meet
the
performance
standards
set
forth
in
EIR
Mitigation
Measure
4.H-4a.
The
physical
Brisbane
Baylands
Final
EIR
2.9.1-94
May
2015