2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
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.
Mitigation
Measure
4.H-1c
states
“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
t
he
most
recent
NPDES
C.3
requirements.”
The
Mitigation
Measure
also
states
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
within
the
Baylands
would
result
in
less
than
significant
impacts
to
water
quality
and
would
not
violate
waste
discharge
requirements.
As
described
in
Draft
EIR
Chapter
3,
Project
Description
,
a
limited
number
of
industrial
uses
are
proposed
as
permitted
uses
under
the
four
Project
site
development
scenarios.
As
a
result,
the
Draft
EIR
provides
a
discussion
of
countywide
NPDES
requirements
related
to
industrial
uses.
All
future
development
will
be
required
to
be
consistent
with
the
provisions
of
the
Brisbane
General
Plan.
Mitigation
Measure
4.H-1c
specifies
the
City
Engineer
as
the
approval
authority
for
Final
Stormwater
Management
Plans
(SMP)
in
accordance
with
NPDES
C.3
requirements,
as
is
the
case
for
other
SMPs
in
the
City.
The
changes
suggested
in
this
comment
are
not
required
for
CEQA
compliance
purposes.
The
underlying
assertion
behind
the
comment
is
factually
incorrect.
The
statement
in
the
Draft
EIR
referred
to
in
this
comment
addresses
potable
water
supplies,
and
the
City
has
no
groundwater
resources
that
provide
a
potable
water
source.
Once
groundwater
enters
the
Bay,
it
is
no
longer
groundwater.
Thus,
use
of
water
in
the
Bay
by
fish,
ducks,
and
invertebrates
living
in
the
Bay
are
not
using
groundwater.
The
threshold
addressed
on
page
4.H-25
is
taken
from
CEQA
Guidelines
Appendix
G,
and
addresses
whether
a
proposed
project
would
result
in
depletion
of
groundwater
tables
such
that
there
would
be
a
net
deficit
in
aquifer
volume
or
a
lowering
of
the
groundwater
table.
Since
groundwater
is
not
proposed
to
be
pumped
as
part
of
proposed
Baylands
development,
no
significant
impact
was
determined
to
exist.
Brisbane
Baylands
Final
EIR
2.9.1-96
May
2015