2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
Figure
4.C-1.
The
Draft
EIR
text
referred
to
in
the
comment
addresses
a
formal
wetland
delineation
conducted
in
2003,
and
noted
that
reconnaissance
level
site
surveys
conducted
in
2011
confirmed
that
the
earlier
wetland
delineation
could
be
used
as
a
source
of
information
to
establish
the
baseline
used
in
the
Draft
EIR
to
assess
impacts.
As
discussed
in
the
pertaining
to
Past
Actions
and
Response
the
Draft
EIR
addresses
impacts
of
future
development
actions.
Activities
that
occurred
prior
to
the
2010
baseline
are
not
the
subject
of
this
evaluation.
The
draft
recovery
plan
for
Callippe
silverspot
butterfly
referenced
in
Comment
is
not
relevant
to
the
Draft
EIR’s
reference
to
the
2003
wetland
delineation.
The
draft
recovery
plan
is
currently
under
development
by
USFWS,
and
has
not
as
of
this
date
been
finalized.
Because
host
plants
have
been
known
to
occur
on
Icehouse
Hill,
once
a
public
draft
is
released
and
ultimately
approved,
implementation
of
the
provisions
of
the
recovery
plan
would
be
applied
to
trail
construction
on
Icehouse
Hill
pursuant
to
the
provisions
of
the
federal
Endangered
Species
Act
in
addition
to
the
mitigation
measures
set
forth
in
the
Baylands
EIR.
The
Draft
EIR
addresses
flooding,
migratory
animals,
nighttime
lighting,
and
impacts
of
horses
at
a
level
of
detail
appropriate
for
a
programmatic
EIR.
As
discussed
above
8,
the
Draft
EIR
provides
habitat-level
analyses
that
are
sufficient
for
analysis
of
impacts
related
to
proposed
Baylands
development
at
this
time.
Additional
analysis
will
be
required
as
part
of
site-specific
development
proposals,
when
precise
areas
of
ground
disturbance
and
building
placement
are
known.
The
host
plants
cited
in
Comment
refer
to
species
in
the
genera,
Lupinus
.
As
they
were
not
observed
during
reconnaissance,
they
were
not
evaluated
in
the
Draft
EIR.
Viola
penduculata
is
acknowledged
as
occurring
on
the
Baylands
Project
Site
on
page
4.C-4
of
the
Draft
EIR.
The
Draft
EIR’s
discussion
of
Impact
4.C-1
regarding
special
status
species
indicates
that
Icehouse
Hill
is
considered
suitable
habitat
for
the
species
referred
to
in
Comment
based
on
the
potential
occurrence
of
compatible,
associated
species
such
as
silver
lupine
(
Lupinus
albifrons
var.
collinus
)
,
summer
lupine
(
L.
formosus
var.
formosus
)
,
and
v
aried
lupine
(
L.
variicolor
).
Analysis
for
Impact
4.C-1
concludes
that
butterfly
larval
host
plants
are
potentially
present
on
Icehouse
Hill,
and
Mitigation
Measure
4.C-1a
requires
preconstruction
surveys
to
ensure
impacts
to
host
plants
are
avoided.
See
regarding
stickleback.
See
which
updates
the
discussion
of
special
Brisbane
Baylands
Final
EIR
2.9.2-34
May
2015