Measure 4.C-1g requires implementation of erosion control and water pollution control measures consistent with SWPPP requirements, and an on-going maintenance plan, to ensure “no reduction in water and environmental quality.” To provide for a broader application of Mitigation Measure 4.C-1e, its first paragraph is revised to read as follows:

Mitigation Measure 4.C-1g: Construction and operation of proposed recreational uses and open space areas along Visitation Creek or adjacent to the northern lagoon edge shall include implementation of erosion control and water pollution control measures consistent with Storm Water Pollution Prevention Program (SWPPP) requirements, and implementation of an on-going maintenance plan to ensure no reduction in water and environmental quality as a result of recreational uses adjacent to within the Creek and lagoon.

BCC-120

[See page 5-187 for the original comment] The comment states that it is also problematic that a SWPPP is a “voluntary compliance” program, and that monitoring required is not necessarily testing the first draw of stormwater from the new rainy season, but that testing is only required if the first rains happen in a convenient 9-5 business time. As a result, the comment notes that the accuracy of tests can be challenged and should not be considered a true reflection of run-off conditions at the Baylands.

Page 4.C-46 of the Draft EIR describes the construction SWPPP mandate, which is not voluntary. The Draft EIR also includes requirements and performance standards beyond the period of construction such as on-going maintenance, including identification of funding for long-term monitoring, maintenance and practical applications such as litter collection and removal that would be required to be established prior to advancing buildout of the Baylands and that would result in water quality benefits by preventing introduction of debris into adjacent water bodies. To clarify how water quality monitoring is to be conducted as part of the SWPPP, the final bullet point in Mitigation Measure 4.C-1g is revised to read as follows.

• Identify a funding mechanism to ensure site maintenance and implementation of environmental quality monitoring at the creek and lagoon as part of the open space interpretive center. Monitoring parameters may shall include but would not be limited to water quality monitoring that at a minimum tests the first draw of stormwater from the new rainy season, and may include, but not be limited to vegetation monitoring, and passive observation and recording of fish species present.

BCC-121

[See page 5-187 for the original comment] The bullet point referred to in this comment is one of several options to protect water quality in the Brisbane Lagoon. Any construction of diversion dikes or drainage swales as part of Baylands development would be required to comply with the provisions of