2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
population
found
on
the
Project
Site
shall
be
verified
at
the
end
of
the
five-year
monitoring
period
established
in
coordination
with
state
and
federal
agencies
with
jurisdiction
over
these
resources.”
This
success
criterion
is
consistent
with
standard
practice
for
determining
impacts
to
rare
plants.
Standard
practice
for
determining
impacts
to
rare
plants
addresses
each
individual
plant
and
the
outcome
of
that
plant’s
response
to
direct
and
indirect
impact,
with
the
stated
goal
of
no
net
loss
because
individual
special
status
plants
are
protected.
It
is
expected
that
at
the
time
of
analysis
for
site-specific
development
projects
and
coordination
with
the
state
and
federal
regulatory
agencies
with
jurisdiction
over
these
resources
that
acreage
calculations
could
be
included
in
mitigation
requirements,
where
appropriate,
when
more
detailed
information
about
the
specific
plants,
including
their
setting
and
relationship
to
adjacent
vegetation
becomes
known.
Direct
impacts
to
be
mitigated
would
include
direct
take
of
one
or
more
individual
plants,
while
indirect
impacts
to
be
mitigated
would
include
changes
to
drainage
patterns
or
other
adjacent
area
conditions
that
would
result
in
loss
or
degradation
of
existing
habitat,
which
is
determined
for
each
affected
plant
to
determine
the
overall
acreage
of
impact
and
needed
mitigation,
which
provides
for
a
more
precise
delineation
of
impacts
than
could
be
addressed
at
this
time.
Mitigation
ratios
for
impacts
such
as
impacts
to
rare
plants
or
suitable
habitat
for
special
status
invertebrates
typically
start
at
a
1:1
replacement
ratio
6
,
as
discussed
in
the
General
Plan
and
Open
Space
Policies,
and
recognize
that
1:1
is
a
minimum
7
.
As
part
of
the
regulatory
process
required
for
all
site-specific
development
reviews,
state
and
federal
regulatory
agencies
will
weigh
in
and
determine
their
mitigation
ratios,
which
are
typically
greater
than
1:1.
The
City’s
General
Plan
and
Open
Space
policies
provide
a
minimum
ratio,
but
do
not
mandate
the
actual
appropriate
mitigation
ratios,
since
those
ratios
are
determined
by
regulatory
agency
staff
per
the
mandates
of
the
state
and
federal
Endangered
Species
Acts.
Mitigation
Measure
4.C-1b
states,
“The
1:1
replacement
ratio
shall
be
met
at
the
end
of
five
years,
and
may
therefore
require
initial
plantings
at
a
greater
than
1:1
ratio...”
This
language
is
included
in
the
Draft
EIR
as
a
means
of
establishing
the
expectation
that
1:1
mitigation
ratio
may
be
exceeded,
but
will
not
be
permitted
to
fall
below
this
minimum
requirement.
The
San
Bruno
Mountain
Habitat
Management
Plan
indicates
that,
“due
to
the
high
cost
and
difficulty
of
propagating
viola,
restoration
of
callippe
habitat
at
this
time
is
likely
better
served
through
large
scale
brush
removal
that
opens
up
grassland
habitat
and
6
7
No
policies
exist
that
specifically
address
mitigation
ratios.
While
the
Clean
Water
Act
is
based
on
a
“no
net
loss
of
wetlands”
policy,
depending
upon
the
quality
of
wetland
habitat
being
impacted,
a
range
of
mitigation
ratios
may
be
appropriate.
Success
criteria
are
established
for
mitigation
monitoring
purposes
after
the
mitigation
ratio
(replacement/restoration
of
x
acres
for
each
acre
impacted).
If
success
criteria
are
not
met,
the
mitigation
measure
is
not
considered
to
be
successful,
no
matter
what
mitigation
ratio
was
originally
established.
Brisbane
Baylands
Final
EIR
2.9.2-42
May
2015